ing indications that existing labels had been removed or defaced but were not immediately marked with the new, required information. In addition to replac- ing the MSDSs with the SDSs, automotive recyclers should make sure to keep the old MSDS forms on file in case of a worker’s compensation claim. How should ARA members comply with this new standard? First and foremost, recyclers must docu- ment all training that is provided, and ensure that there is a framework in place for review of new SDS

and label information when revisions are received in the workplace for products already in use, as well as for any new products that are added to the facility. Any new information will also need to be provided to employees, and that process must be documented. Your ARA has resources to help you comply with this new standard, which is included in the Association’s CAR Program.

In addition, the Automotive Recyclers Association’s Safety Committee is staying on top of these issues. The Committee Chair, ARA Past President Doug Reinert, is well-versed on the new HCS standard and acts as a resource to the ARAUniversity as it continues to update its training curriculum on hazardous chemical management. In fact, the Safety Committee addressed the HCS issue in one of its Safety Tips (illustrated at left). They have released other Safety Tips that are available from ARA.

The ARA CAR Program is also a valuable resource to recyclers on the HCS requirements. As well, addi- tional information on the revised Hazard Communi- cation Standard may be found on OSHA’s Hazard Communication Safety and Health Topics page at http://www.osha.gov/dsg/hazcom/index.html.

September-October 2015 | Automotive Recycling 53