MSDSonline - EH&S Compliance Made Simple

David Michaels Voices Strong Support for Further EPA Alignment with GHS

Nov 29, 2016

OSHA head Dr. David Michaels has issued a letter encouraging the EPA to include alignment with GHS among its forthcoming revisions to the Toxic Substances Control Act (TSCA).

Part of the proposed EPA changes regarding Significant New Use Rules (or SNURs) would mandate that any SNURs issued in the future “require that a written hazard communication program be developed and implemented for the substance in each workplace in accordance with 29 CFR 1910.1200, the [GHS-aligned] OSHA HCS.” The revisions also propose that, “The specific statements and warnings that could be required [for SNURs] would be based on EPA’s risk assessment of the chemical substance and would be consistent with the OSHA HCS and GHS recommendations.”

Should the EPA align all or part of its revisions to the TSCA with GHS, it would be yet another step toward greater overall harmony between the EPA and OSHA — a journey which has hit several important milestones this year. In June, the EPA issued revisions to reporting requirements under the Emergency Planning and Community Right-to-Know Act (EPCRA) to make them more compatible with OSHA’s GHS aligned HCS. Specifically, the revised requirements mandated that facilities submit either GHS aligned SDSs or a list of chemicals grouped into categories as laid out under the GHS to their State Emergency Response Commission, their Local Emergency Planning Committee, and to local first responders as part of required Tier II reporting. The EPA also elected to replace its existing hazard category system with the hazard classes used in the OSHA HCS. In this connection, Tier II reports submitted by March 1, 2018 for the 2017 calendar year will need to reflect the HCS hazard categories as now adopted by the EPA using print or electronic reporting formats which will be made available before that time.

According to Dr. Michaels, further aligning TSCA revisions with GHS could make things even easier for businesses seeking to comply with both EPA and OSHA regulations.  As Dr. Michaels states in his letter:

“OSHA modified the HCS in 2012 to conform to the United Nations’ Globally Harmonized System of Classification and Labelling of Chemicals (GHS). The GHS provides a common and coherent approach to classifying chemicals based on their hazardous properties and communicating hazard information to workers. By cross-referencing and ensuring consistency with the OSHA HCS, the proposed [TSCA] changes reduce duplication in effort and burden for those subject to these requirements.” 

The Frank R. Lautenberg Chemical Safety for the 21st Century Act (the Lautenberg Act) was signed into law by President Obama in June of this year. It requires the EPA to evaluate existing chemicals with clear and enforceable deadlines, introduces a risk-based safety standard, and increases transparency around some chemical information. In October, the EPA announced that it was moving to fast-track its first five chemicals reviewed under the Lautenberg Act.

This is not the first time that Dr. Michaels has written to the EPA with input regarding the TSCA. In an undated letter from earlier this year, Dr. Michaels argued that the EPA may be more effectively positioned than OSHA to enforce chemical safety standards in certain situations, under the authority of the TSCA:

“Given certain limitations imposed on OSHA’s authority under the OSH Act, this agency believes TSCA provides the Environmental Protection Agency (EPA) with a means of eliminating or reducing the risks associated with these chemical uses in a more coordinated fashion . . .”

Whatever the EPA ultimately decides to do regarding GHS-alignment of the TSCA, cloud-based compliance management solutions from VelocityEHS allow your business to quickly and easily adapt to any regulatory changes that lie ahead. Our EHS management solutions give you the ability to assign and schedule tasks, track follow-ups, and send escalating notifications to employees when required actions are upcoming or past due. With VelocityEHS, you gain the visibility and control you need to manage your chemical inventory more effectively, and maintain compliance across your facilities. With the right solutions in place, you can be prepared to meet any obligations that may arise following revisions to the TSCA — along with your other EHS compliance requirements.


Leave a comment
  1. 0800 company | Mar 29, 2017
    Great post! I am actually getting ready to across this information, is very helpful my friend. Also great blog here with all of the valuable information you have. Keep up the good work you are doing here. 0800 company
  2. Jackson | Mar 29, 2017

    [url=]download software[/url]

  3. Leo | Mar 29, 2017
    Great Post, I'm a large believer within posting comments upon sites in to allow blog site writers recognize that additional some thing valuable in to the internet! 
    <a href=>download software</a> 
  4. jamsmalik | Mar 28, 2017
    Kirk Hammett Rig Rundown. Starting with one of his signature model ESP guitars will give you a great foundation. The fact that he uses pretty common amps and effects pedals makes his tone rather transparent. However, if you are aiming to completely copy his setup and tone color, you might need to dwell a bit deeper into his preferences and specific gear he used for the album you are interested in. With that said, Hammett’s energy and level of emotion he infuses into his performance, is still one of the best things about Metallica. yngwie malmsteen guitar setup
  5. muneer | Mar 27, 2017
    I'm constantly searching on the internet for posts that will help me. Too much is clearly to learn about this. I believe you created good quality items in Functions also. Keep working, congrats!
  6. Dota | Mar 26, 2017
    just what most individuals' desire. However, most of which have no idea of the inner thoughts and multi-step means of purchasing a fresh home Dota
  7. muneer | Mar 23, 2017
    Thanks for sharing this information. I really like your blog post very much. You have really shared a informative and interesting blog post with people.. itunes games
  8. Case study solutions online | Mar 22, 2017
    Case study solutions online I would like to thank you for the efforts you have made in writing this article. I am hoping the same best work from you in the future as well. Thanks
  9. jamsmalik | Mar 21, 2017

    It proved to be Very helpful to me and I am sure to all the commentators here! 

  10. muneer | Mar 16, 2017
    The website is looking bit flashy and it catches the visitors eyes. Design is pretty simple and a good user friendly interface. Choices Stories You Play Cheats
  11. muener | Mar 09, 2017
    Thanks for the tips guys. They were all great. I have been having issues with being fat both mentally and physically. Thanks to you guys i have been showing improvements. Do post more. ONE PIECE THOUSAND STORM Hack
  12. muener | Mar 08, 2017
    This is a wonderful article, Given so much info in it, These type of articles keeps the users interest in the website, and keep on sharing more ... good luck. download freeware
  13. thereserbax | Mar 07, 2017
      That’s what I was looking for.Very nice blog indeed,thank you admin python quiz
  14. jamsmalik | Mar 06, 2017
    I admit, I have not been on this web page in a long time... however it was another joy to see It is such an important topic and ignored by so many, even professionals. professionals. I thank you to help making people more aware of possible issues. tattoo salon
  15. free steam games | Mar 05, 2017
    These keys and codes can be purchased online from steam website steam gift cards steam is the store or market place where thousands of games are available.
  16. muneer | Mar 04, 2017
    I think this is an informative post and it is very useful and knowledgeable. therefore, I would like to thank you for the efforts you have made in writing this article. instagram search
  17. muenerm | Mar 02, 2017
    Thanks a lot for sharing us about this update. Hope you will not get tired on making posts as informative as this. wedding photography

    Leave a comment

    Follow Us


    “Flexible, convenient, easy to use and explain to the employees. Great time saver over the old paper system that had.  I am very happy with the experience; from building the file to the roll out to the employees.”

    Mike Fergurson, Cope Plastics, Inc