OSHA has provided additional clarity and guidance to chemical blenders who rely on downstream SDS information from their suppliers. Previously, chemical blenders were caught in a no win situation. If they need to re-author their MSDS's into the new SDS/GHS format by June, 2015, how can they comply if they have not received the updated SDS from their suppliers? Thanks to the American Coatings Association and others, OSHA has given gudanceand has also allowed for some discretion on the part of enforcement staff.
If the blender has documented their requests for updated information from their suppliers and have not received the updated SDS yet, and if they have made reasonable efforts to find another supplier who is able to provided the updated SDS, then 'OSHA is able to use its enforcement discretion when compliance staff consider wether formulators and manufacturers have their due diligence and made good faith efforts to obtain necessary information to comply with the June 1, 2015 deadline'.
To see the OSHA letter, please click here: http://www.m3vsoftware.com/OSHA-Clarifies-2015-Deadline-Chemical-Blenders.asp