In one of the most significant rulemaking efforts in over a decade, OSHA is proposing to revise its hazard communication standard to align it with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS). If finalized, the rule would affect over 5 million business establishments across the country and potentially over 120 million employees. Over 40 million employees would need to be trained on hazard communication under the proposal. OSHA estimates the annualized compliance costs will be almost $100 million for employers. Annualized benefits are estimated to be approximately $850 million.

Because of the broad scope of the proposed rule, all employers are encouraged to familiarize themselves with the requirements and participate in the rulemaking process. Comments on the proposal must be submitted to OSHA by December 29, 2009.

Attached is a Special Report on the proposed rule that summarizes its key provisions.

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Photo of Bradford T. Hammock Bradford T. Hammock

Brad Hammock is a Principal in the Washington, D.C. Region office of Jackson Lewis, practicing exclusively in the safety and health area. He heads Jackson Lewis’ Workplace Safety and Health practice group.

He joined the firm in 2008 after serving for ten years…

Brad Hammock is a Principal in the Washington, D.C. Region office of Jackson Lewis, practicing exclusively in the safety and health area. He heads Jackson Lewis’ Workplace Safety and Health practice group.

He joined the firm in 2008 after serving for ten years as an OSHA attorney within the Department of Labor including, most recently, for more than three years as lead counsel for safety standards. As lead counsel, Mr. Hammock managed attorneys who worked with OSHA on regulatory initiatives, compliance assistance, and enforcement policy. He had direct responsibility for more than 20 major OSHA regulatory initiatives, including rulemakings on personal protective equipment, confined spaces, and crane safety.

Before his promotion to lead counsel, Mr. Hammock worked as a regulatory attorney for OSHA, focusing on ergonomics. He was one of the lead attorneys during the development of the OSHA ergonomics standard in 2000 and had primary responsibility for the Department of Labor’s comprehensive approach to ergonomics in 2002. Mr. Hammock is widely regarded as one of the nation’s most experienced attorneys on ergonomics.

Education

  • University of Virginia/Bachelor of Arts in American Government/1992
  • Syracuse University College of Law/Juris Doctor, magna cum laude/1996

Bar Admissions

  • District of Columbia
  • Virginia