In 2012, the Occupational Safety and Health Administration (“OSHA”) revised the Hazard Communication System (“HCS”) and other regulations to conform them to the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (“GHS”). Fed. Reg. Vol. 77, No. 58, p. 17573 et seq. (5/15/12). By Dec. 1, 2013, employers must have trained their workers on new chemical labeling requirements and the new format for Safety Data Sheets (formerly known as MSDSs).

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