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Stephanie Salmon, AFS Washington Office; Jeff Hannapel & Christian Richter, The Policy Group, Washington, D.C.

OSHA Issues New Hazard Communication Standard Inspection Directive


In 2012, OSHA revised

the Hazard Communica- tion Standard to align with the United Nations Glob- ally Harmonized System of Classification and Labelling of Chemicals (GHS). Te goal of the revisions was to improve the quality, consistency and clarity of chemical hazard information that workers receive. Among the revisions: • Chemicals must now be classi- fied according to specified hazard criteria.

• Chemical container labels must contain hazard pictograms and other key information.

• Safety data sheets must be written in a specified 16-section format.


Over 5,000 Companies Made Reports to OSHA Under New Reporting Rule

According to the Occupational Safe- ty and Health Administration (OSHA), the agency has received 5,474 notices for the first six months of the year since its new injury reporting rule took effect on January 1. The rule requires employ- ers, including foundries, to notify OSHA within 24 hours whenever a worker is admitted to a hospital, suffers an ampu- tation or loses an eye. Previously, OSHA had to be contacted only when three or more workers were hospitalized. OSHA defines amputation as including the loss of a fingertip without bone loss. Dr. David Michaels, the Assistant Secretary of OSHA, stated last month that about 40% of the reports have prompted an OSHA inspection, while another 46% have resulted in OSHA contacting the employer to learn more about the incident. OSHA is utilizing a mechanism known as a “rapid response investigation (RRI),” where the agency

20 | MODERN CASTING August 2015

is asking the employer to investigate the accident to determine how it happened and what corrective measures were imple- mented to prevent a recurrence. A RRI starts with a “non-mandatory” two-page questionnaire for the employer to complete with a request for a “root cause” analysis of the incident to identify failures in safety procedures. The company is requested to respond to the RRI within a week. OSHA is in the process of creating a searchable database from the data submitted by companies from each report. The database would include: a) informa- tion about the injury, b) the circumstances surrounding it, and c) how the employer reduced associated hazards. The data- base would be similar to injury and fatality information offered online by the Bureau of Labor Statistics.

Tax Extenders Package Progress Efforts are underway in Congress to extend through 2016 a number of tax provisions important to the metalcasting

industry including enhanced Section 179 expensing, first-year 50% expensing (known as bonus depreciation), the R&D tax credit and deferral for active financ- ing income. AFS has urged lawmakers to extend these provisions before the end of the year in order to provide certainty with business planning concerning capital in- vestments and R&D. These temporary tax provisions expired at the end of last year, just days after Congress retroactively renewed them for tax year 2014. In Congress, the Senate Finance Committee approved a two-year exten- sion of the expired tax provisions in July to serve as bridge until the Congress acts on comprehensive tax reform. Earlier this year, the full House of Representatives passed individual bills to make permanent the R&D tax credit as well as enhanced Section 179 expensing. AFS will continue to be engaged in this issue.

For additional information, contact Stephanie Salmon, AFS Washington Off ice,


ing provisions as long as they are not relabeling materials or creating safety data sheets (SDS), in which case they must comply with the June 1 deadline. Te directive outlines how

the revised HazCom standard is to be enforced during its phase-

Te revised Hazard Communication

Standard required employers, including foundries and suppliers, to train work- ers on the new label elements and safety data sheets by December 2013. Chemical manufacturers, importers and distribu- tors had to comply with revised safety data sheet requirements by June 2015. Manufacturers and importers had to comply with new labeling provisions as of June 1, 2015. Distributors have until December 1, 2015, to comply with label-

in period and after the standard is fully implemented on June 1, 2016. In the directive, OSHA states that the agency typically will not cite chemical manu- facturers, importers and distributors that lack a GHS-compliant SDS or label if these companies can show that they “have exercised ‘reasonable diligence’ and ‘good faith’ to obtain HCS 2012-com- pliant SDSs from upstream suppliers but have not received them.” Te new direc- tive is available at

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