OSHA Update
Joel G. Newman, president and CEO
Wednesday, March 11, 2015
by: Joel G. Newman, president and CEO

Section: Spring 2015

The American Feed Industry Association is in the final stage of completing a guidance document and Model Safety Data Sheets (SDS), which will walk members through the Occupational Safety and Health Administration Communication Hazard Communication Standard (updated March 2012) and its requirements related to feed, pet food and ingredients. The update conforms with the United Nations Globally Harmonized Standard for Communications of Chemicals (GHS), which is referenced in the rule.  
As the feed industry labeling of products is regulated by the U.S. Food and Drug Administration (defined in the Federal Food Drug and Cosmetic Act), bulk and bagged feed and ingredient products are exempt from the OSHA labeling requirements of HCS (labeling of products cannot be regulated by two agencies). However, that does not automatically preclude the industry from the need to provide a SDS for certain feed or ingredient products, which is determined by the individual company and the products they process/sell. The AFIA guidance document will walk members through a decision tree that will help in making this determination. A Model SDS will also be included with guidance for those companies with products that require an SDS.
AFIA will publish the finalized document for our members this spring. The compliance date for the standard is June 1. AFIA’s expert staff will also provide additional assistance with any questions on the process, and the association is now working with Christian Richter, an outside consultant, who will assist the AFIA team with OSHA-based issues. 
Richter has nearly 20 years of experience in the field, and AFIA is confident that Richter is an excellent addition to AFIA’s consulting experts and will help to keep AFIA membership informed on regulatory issues affecting the industry. 
Founder and CEO of The Policy Group, Washington, D.C., Richter provides consulting services to trade associations in areas regarding environmental, health, defense, workplace and related issues. Prior to The Policy Group, he served as President of Navista, Inc., and Vice President of Legislative and Regulatory Affairs for National Environmental Strategies. 
Richter received his bachelor’s degree and master’s degree in economics and policy analysis from the University of Wisconsin in Madison, Wis. 
For more information on AFIA’s soon-to-be-released guidance document and Model SDS, or general OSHA issues, contact AFIA President and CEO, Joel G. Newman at jnewman@afia.org.
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