Sarah Lindsey, Staff Scientist at Schneider Risk Management
SRM & Associates LLC.
In 2012, OSHA updated its Hazard Communication regulation (29 CFR 1910.1200) to align with the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS), Revision 3. Some deadlines have already come and gone, and there are two deadlines left that you may need to be aware of: Chemical Distributors have until December 1, 2015, to update and ship all products under the new labeling requirements, and Chemical Users / Employers have until June 1, 2016 to finalize labeling and plans.
I have less than the threshold quantity of Anhydrous Ammonia. What does the EPA Enforcement Alert mean for me?
Vicki Schneider, Principal Consultant at Schneider Risk Management
As we shared with you in a previous article, the U.S. EPA (EPA) issued an Enforcement Alert (February 2015) describing how facilities using anhydrous ammonia are under scrutiny by EPA. The Alert primarily addressed facilities that contain anhydrous ammonia above the threshold quantity (TQ) of 10,000 lbs.; however, these warnings should not be ignored by those companies with systems under the TQ.