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NACD Press Release

Arlington, VA
December 14, 2021

Aileen Smith

NACD Warns Against OSHA Changes to Hazard Communication Standard Safety Data Sheets

Arlington, VA – Today, the National Association of Chemical Distributors (NACD) sent a joint letter to U.S. Secretary of Labor Martin J. Walsh and Assistant Secretary of Labor Douglas L. Parker raising concerns over the Occupational Safety and Health Administration’s (OSHA) proposed changes to its Hazard Communication Standard (HCS) regarding Safety Data Sheets (SDS).

The letter, penned by members of the Council of Chemical Association Executives, raises concerns over proposed changes to Section 2 of the SDS, which would significantly expand the scope of the HCS, add needless complexity and liability to the system, and undermine the HCS’s own goals of seeking to communicate chemical hazard data to assure worker protection.

“NACD members are deeply committed to worker safety and take every step to support the HCS’s goals of providing workers with knowledge and understanding of the chemical hazards in their workplaces,” said NACD President and CEO Eric R. Byer. “But requiring distributors to include any possible downstream hazards in their Safety Data Sheets would further complicate an already thorough process and would be counterproductive to the rule’s goal of providing clear information to workers.”

OSHA’s proposed changes to Section 2 would cause U.S. regulations to conflict with the greater Globally Harmonized System of Classification and Labeling of Chemicals used throughout the world. Rather than facilitating alignment, the change would leave the U.S. rules even more divergent from the global system.

NACD looks forward to working with the Department of Labor and OSHA in implementing a hazard communication system that provides transparent information to workers without additional, unnecessary burden.

Read the full letter here.


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. For more information on NACD, visit