Larry Halprin Presentation to the Can Manufacturing Institute Members

On April 6, 2021, from 11:00 AM – 12:00 PM EDT, Larry Halprin from Keller and Heckman will present to CMI members on U.S. OSHA’s proposed rulemaking (“NPRM”)  to update the agency’s Hazard Communication Standard (“HCS”) to align with the 7th edition of the United Nation’s (UN) Globally Harmonized System of Classification and Labelling of Chemicals (GHS).  

During the webinar, Mr. Halprin will present on the proposed rulemaking, including:

1. Proposed infeasible changes to the scope of the required classification determination to address all downstream uses (including changes in physical form and chemical reactions) and their potential adverse impact on harmonization, compliance, compliance burden, the effectiveness of HazCom programs, and liability under tort law;
2. Proposed positive changes in labeling obligations (for product released for shipment prior to required label updates, bulk shipments, and small packaging);
3. Ability to protect confidential concentration information from disclosure (specific concentration and ranges, mandatory disclosure to expanded medical professional group); and
4. Impact of revised classification criteria.