New 2025 workplace regulatory and safety briefs that CDMS wants you to know.
For our clients that use and ship chemicals:
1. Hazardous Communication Standard (29 CFR 1910.1200) for chemical manufacturers, importers and employers has been updated.
What do employers need to know?
CDMS wants to inform our clients that OSHA has adopted the 7th Revised Edition of the Globally Harmonized System of Classification and Labeling of Chemicals” (GHS), which includes criteria for the classification of health, physical and environmental hazards, as well as specifying what information should be included on labels of hazardous chemicals as well as safety data sheets. OSHA amended the HazCom standard to better align requirements with U.S. trading partners and to correct or clarify some points in the existing regulation. The GHS is updated every two years, and with this updated rule, OSHA is seeking to conform its HCS to the 2017 revision of the GHS. With this, there has been some modifications to the classification of some chemical hazards.
CDMS’ Right-To-Know training will reflect the 7th Revised Edition GHS changes.
2. e-Manifests are now required for hazardous waste generators
What do generators need to know?
Originally introduced in 2018, California generators of hazardous waste were given the option of using the EPA’s e-Manifest system for both RCRA and non-RCRA waste.
Beginning January, 22, 2025, both Large and Small Quantity Generators must register for e-Manifest. Registering is easy using the RCRAInfo portal.
For all our clients with 11 or more employees during the 2024 calendar year:
3. OSHA 300A summary forms must be posted by February 1, 2025
What do employers need to know?
To find out if you are required to prepare and maintain records under the updated rule, first determine your NAICS code by: Using the search feature at the U.S. Census Bureau NAICS main webpage. In the search box for the most recent NAICS, enter a keyword that describes your business. Choose the primary business activity that most closely corresponds to you, or refine your search to get more choices. Once you have found your NAICS code, you can use Table 1 below to determine if your industry is exempt from the recordkeeping rule. Postings must remain
in a visible location where employees can easily see it, usually in a break room, near a time clock, or company bulletin board. The postings can be removed after April 30th , but it is important to keep the records in a secure location. If you need any assistance with this, please contact your CDMS representative for assistance.
Employers have a duty to train their employees
As required by section 3203 (Injury, Illness, and Prevention Program), the employer shall establish and implement a system for communicating workplace hazards in a language and manner readily understandable by employees, including provisions designed to encourage employees to inform the employer of lead exposure hazards at the worksite without fear of reprisal.
CDMS’s Role:
CDMS continues to provide and update training and plan development to our California clients. If you would like an assessment of your current plan, or questions about Title 8 §5155 and §5198, please reach out to service@cdms.com.
