PRINTING United Alliance Submits Comments to OSHA on Hazard Communication Standard Proposal

The Occupational Safety and Health Administration (OSHA) released a proposal to revise the Hazard Communication Standard (HCS), a key OSHA regulation addressing chemical safety that applies to all printing operations. OSHA’s proposed changes seek to update the HCS to align its rules with those in the seventh version of the United Nation’s Globally Harmonized System of Classification and Labeling of Chemicals (GHS), published in 2017. The current version of the HCS, last revised in 2012, is based on the third version of the GHS program.

OSHA’s proposed modifications to the Haz Com Standard include codifying enforcement policies currently in OSHA’s compliance directive, clarifying requirements related to the transport of hazardous chemicals, adding alternative labeling provisions for small containers, and adopting new requirements related to preparation of Safety Data Sheets.

In its comments, PRINTING United Alliance raised serious concerns with the proposed language that would require chemical manufacturers and importers to consider all potential downstream uses of a chemical in the workplace.  The Alliance stated that “This newly proposed language is impossible for manufacturers and importers to meet as they cannot know how a downstream customer, or a customer of a customer will use their product. This requirement goes far beyond current global practices established for hazard classification that is to assess the hazards of the chemical as shipped without considering downstream chemical reactions.” 

The Alliance also took the opportunity to once again petition the Agency to revise its in plant labeling methods for portable containers to allow for color coding of containers.  In 2017, a request for a letter of interpretation was sent to OSHA to allow them to recognize that using a color coding and workstation chart system be deemed functionally equivalent to having a label on a container. To support the requested change in regulation, the comments included a copy of the letter submitted in 2017.

OSHA has set a date of September 21, 2021 to hold a public hearing on its proposed rule to amend the Hazard Communication Standard.  PRINTING United Alliance has requested a time slot so it can participate in this virtual hearing.

For a complete copy of the submitted comments, or if you have any questions, please contact Marci Kinter at or Gary Jones at

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