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December 18, 2023

Harmonizing TSCA Consent Orders with OSHA HCS 2012, May 14, 2024, 11:00 a.m. – 12:00 p.m. (EDT), via webinar

Bergeson & Campbell, P.C.

Bergeson & Campbell, P.C. (B&C®) and The Acta Group (Acta®) presented “Harmonizing TSCA Consent Orders with OSHA HCS 2012,” a complimentary webinar covering case studies and practical applications of merging the requirements for consent order language on the Safety Data Sheet (SDS).

Toxic Substances Control Act (TSCA) consent orders and Significant New Use Rules (SNUR) are issued under Section 5 for specific chemicals. These U.S. Environmental Protection Agency (EPA) consent orders and SNURS often include requirements to add hazard communication language to SDSs. Communicating this language to commercial partners can be challenging as implementing these measures must be harmonized with requirements under the U.S. Occupational Safety and Health Administration’s (OSHA) Hazard Communication Standard (HCS). Simultaneously fulfilling the requirements of both TSCA and OSHA HCS is critical for companies that are preparing HCS elements for products used in the workplace. This webinar explores these challenges and offers suggestions to resolve them.

In this webinar, Karin F. Baron, MSPH, Director of Hazard Communication and International Registration Strategy, B&C, explore two hypothetical examples and provide guidance on practical approaches to compliance. An industry perspective was presented by Sara Glazier Frojen, Senior Product Steward, Hexion Inc., who discussed the realities of managing this process day-to-day.

Topics Covered:

  • Background on OSHA HCS 2012 and TSCA consent orders and SNURs
  • Discussion using hypothetical examples from TSCA consent orders
    • High molecular weight polymer
    • Pyrolysis oil
  • Practical applications from industry perspective

Speakers include:

Sara Glazier Frojen, Senior Product Steward – Environmental Health & Safety, Hexion Inc., has a master’s degree in polymer chemistry and joined Hexion 12 years ago as a research and development chemist. She transitioned to product stewardship eight years ago where her current focus is on raw material review, substance hazard evaluation, new substance development, substance registration, regulatory compliance, and emerging regulations.

Karin F. Baron, MSPH, Director of Hazard Communication and International Registration Strategy with B&C, has more than 20 years’ experience developing, implementing, and managing complex chemical regulatory compliance strategies for some of the largest industrial and specialty chemical companies in the world. Her primary areas of practice include navigating the Globally Harmonized System of Classification and Labeling of Chemicals (GHS), including classification, labeling, and authoring of compliant SDSs, hazard and risk assessment, industrial hygiene, and environmental health and safety (EHS) programs.

Lynn L. Bergeson, Managing Partner, B&C, has earned an international reputation for her deep and expansive understanding of how regulatory programs pertain to nanotechnology, industrial biotechnology, synthetic biology, and other emerging transformative technologies. Ms. Bergeson counsels corporations, trade associations, and business consortia on a wide range of issues pertaining to chemical hazard, exposure and risk assessment, risk communication, minimizing legal liability, and evolving regulatory and policy matters.