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NACD Press Release

Arlington, VA
September 22, 2021

Aileen Smith

NACD Raises Concerns Over Proposed Changes to OSHA Hazard Communication Standard

Arlington, VA – Yesterday, National Association of Chemical Distributors (NACD) Vice President of Regulatory Affairs Jennifer C. Gibson testified before the U.S. Occupational Safety and Health Administration (OSHA) regarding proposed changes to the administration’s Hazard Communication Standard.

“Revisions to the Hazard Communication Standard (HCS) have a huge impact on NACD members. Chemical distributors serve a critical role in the middle of the supply chain, and these companies have large numbers of suppliers, products, and customers. Changing safety data sheets and labels for thousands of chemical products is a major undertaking for distributors."

“While NACD agrees with OSHA’s objective to harmonize the HCS with the United Nations Globally Harmonized System of Classification and Labeling of Chemicals and supports some of the agency’s proposed changes, we have serious concerns about others. Some of the proposed changes are not necessary for harmonization and would create excessive burdens for chemical manufacturers and distributors without providing comparable, if any, worker protections.

“NACD appreciates the opportunity to provide input on OSHA’s proposed revisions to the Hazard Communication Standard. These changes will have a substantial impact on chemical distributors, and NACD encourages OSHA to consider seriously the issues and concerns, including commercial confusion likely to result from the new proposed definitions for “bulk shipment” and “released for shipment,” requiring new labels with dates for every different product shipment date, inadequate implementation time, and others raised in our testimony and written comments.”


NACD and its over 400 member and Affiliate companies are vital to the chemical supply chain providing products to over 750,000 end users. NACD members are leaders in health, safety, security, and environmental performance through implementation of Responsible Distribution, established in 1991 as a condition of membership and a third party-verified management practice. NACD was established in 1971 and is celebrating its 50th anniversary this year. For more information on NACD and how the association is Celebrating 50 Years, visit