In fact, the information and training requirements are flexible, just a woman who loves cats and wine retro poster and do not specify how the training is to be accomplished. If an employer only has a few chemicals,
just a woman who loves cats and wine retro poster
In this regard the Hazard Communication Standard has added very few additional training responsibilities. OSHA’s cost estimates focus only on new duties, just a woman who loves cats and wine retro poster not on the burdens of pre-existing standards. So the cost estimate for the expanded rule does not assume the costs for training that should have been conducted to comply with 1926.21. Employers who were not in compliance with that rule, or with the requirements of the states they are operating in, will have to spend more to comply than has been estimated. However, that is not a cost that is attributable to the HCS. The current final rule is merely a minor revision of the HCS which already applies to all industrial sectors where workers are exposed to hazardous chemicals.
This revision is not a major or significant rule, thus no additional regulatory impact analysis is necessary. As noted in the NPRM (53 FR ), the analyses performed prior to publication of the 1987 final rule, which is currently being enforced, are not being revised. However, as comments were submitted concerning the costs of the current provisions, OSHA is taking this opportunity to briefly discuss some of the issues that have been raised. A substantial portion of the comments received from the construction industry maintain that the training is infeasible in their industry. This claim of infeasibility is based upon their interpretation that the employer must train each worker on the MSDS on each chemical, and thus would have to stop the work on the job each time a new contractor comes on the site with new chemicals to re-train all employees on those chemicals. (See, e.g., Exs. 11-6, 11-15, 11-73, 11-98, .)
18×12, 24×16, 36×24, 48×32