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NACD Press Release

Arlington, VA
May 19, 2021

Lucinda Schofer
(571) 482-3044

National Association of Chemical Distributors Raises Substantial Concerns Regarding Proposed Changes to OSHA Hazardous Communication Standard


Arlington, VA – Today, the National Association of Chemical Distributors (NACD) submitted comments in response to the proposed rule published by the U.S. Occupational Safety and Health Administration (OSHA) regarding Docket No. OSHA-2019-0001, Hazard Communication Standard (HCS).

While supportive of the overall objective, NACD has substantial concerns regarding some of OSHA’s proposals to harmonize the HCS with the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS).

“Revisions to the HCS have a huge impact on NACD members,” said NACD President and CEO Eric R. Byer. “Chemical distributors serve a critical role in the middle of the supply chain, and most of these companies have large numbers of suppliers, products, and customers. Changing safety data sheets (SDSs) and labels for hundreds or even thousands of chemical products is a major undertaking for these companies.”

One NACD member estimates they have 10,000 SDSs to review to meet the new standard and 4,000 to update. Even at OSHA’s .7 hours per SDS estimate, that is 16 months of dedicated work. NACD members are predominantly small regional businesses, many of which are multi-generational and family-owned. Some of the proposed changes are not necessary for harmonization and would create excessive burdens for chemical manufacturers and distributors while adding needless complexity and liability to the system.

NACD encourages OSHA to seriously consider the issues and concerns raised in the association’s comments, including proposed changes, implementation, and timelines, to ensure effective harmonization of important hazard communications standards while protecting businesses large and small from undue burdens.


NACD and its nearly 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, visit

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