By Eric J. Conn and Casey M. Cosentino
For years, OSHA’s Hazard Communication Standard (“HazCom”) has been the standard most frequently cited against hotel and other hospitality employers.
In FY 2011 37 hotel companies were cited for violations of the HazCom Standard, including, primarily, alleged failures to:
(1) maintain a written Hazard Communication Program;
(2) ensure each container of hazardous chemicals (such as cleaning agents) is labeled, tagged, or marked;
(3) maintain a complete set of Material Safety Data Sheets (“MSDS’s”) for each hazardous ...
By Eric J. Conn and Casey M. Cosentino
Following a March 20, 2012 Press Release, on March 26, 2012, OSHA issued its much anticipated final Hazard Communication Rule ("HazCom"), which integrates the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (“GHS”) into OSHA’s old Hazard Communication Standard (“HazCom” or "HCS"). The new HazCom Standard requires employers to classify chemicals according to their health and physical hazards, and to adopt new, consistent formats for labels and Safety Data Sheets (“SDS’s” ...
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