Lawrence Halprin Quoted in an Inside TSCA Article on OSHA’s Final ‘Hazard’ Rule

Keller and Heckman Partner Lawrence Halprin was quoted in the Inside TSCA article, “OSHA Readies Final ‘Hazard’ Rule Seen Driving ‘Vast’ Chemical Data Mandate.” The article discusses the Occupational Safety and Health Administration (OSHA) finally sending a long-pending rule to update its chemical hazard communications standard (HCS) for White House review. OSHA first proposed the revisions in February 2021.

According to Lawrence, OSHA could use the HCS to gather data far beyond the program’s original purpose, including toxicity, use, and exposure information – which he suggested could be transferred to the U.S. Environmental Protection Agency (EPA) to be applied in the Toxic Substances Control Act (TSCA).

“Finally, it appears that OSHA seeks to maintain its primary but diminished role in the area of workplace chemical safety,” Lawrence wrote in a 2021 Keller and Heckman publication, “and implement its recent Memorandum of Understanding with EPA, by requiring chemical manufacturers to develop all information that EPA could conceivably require” to help gauge chemical risks.

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