SC&RA Expresses Concern Over Compliance Costs on Hazard Communication Standard
(May 26, 2021) - SC&RA, through its membership in the Construction Industry Safety Coalition (CISC), submitted
comments May 19 to OSHA regarding its proposed rule to amend the Hazard Communication Standard codified at 29 C.F.R. § 1910.1200.
In general, the Coalition supports OSHA’s adoption of the United Nations’ Globally Harmonized System of Classification of Labeling of Chemicals (HCS), a system that provides a common, coherent approach to classifying and communicating chemical hazards. However, it is concerned with the familiarization, training, and compliance costs imposed on the construction industry by continuous updates to OSHA’s HCS.
SC&RA has concerns regarding the costs to small businesses, which are common within the construction industry. Even though such businesses are generally only end users of these chemicals, they still incur regulatory costs associated with updates to the HCS. It is important that OSHA recognize the full impact of its proposal, including its reach in the construction industry, and provide significant compliance assistance to construction companies. Alternatively, the CISC requests that OSHA clarify that a final rule would not impact construction and construction contractors would not be obligated to change their written hazard communication programs accordingly.
The CISC is comprised of SC&RA, along with 29 other trade associations representing virtually every aspect of the construction industry. The CISC was formed several years ago to provide data and information to OSHA on regulatory, interpretive, and policy initiatives. For more information, contact
Beth O’Quinn.