The new HAZCOMM 2012 ‘Right to Understand’ will impact 5 million businesses at an OSHA estimated cost of only $201 million dollars.
Thats just $40 per workplace to cover:
- Cost of classifying Chemical hazards to meet the new GHS criteria;
- Cost to revise Safety Data sheets and labels to meet the new format and content requirements;
- Cost to train 43 million employeeson the new format and content of material symbols and data sheets;
- Cost to management of those 5 million workplaces to become familiar with the new GHS requirements, assess, revise, develop and implement new compliance materials needed to adopt GHS;
- Cost for printing new packaging and labels in color;
OSHA thinks that we can do it for $201 million a year- that’s just $40 per workplace!
Using Department of Labor enforced Federal Minimum Wages, $7.25 an hour, that means that they think that it will only take 5,5 hours to get a shop into compliance.
(Please, correct my math if I’m wrong!)
The PDF of the final rule is 858 pages!
Just to read that in 5.5 hours would mean reading 156 pages per hour.
At a nickel a page, just printing the final rule puts us over at $42.90.
Who the heck does these estimates? What were they thinking?
We really understand that regulations can provide a benefit to workers, companies and communities.
Especially where hazardous chemicals are involved.
But when the regulators underestimate the potential costs of adoption and compliance by such a large factor, it makes us wonder what other assumptions are they working under that are just as wrong?
P.S. Do you think that OSHA or OIRA actually have employee’s that can read 156 pages of federal technical regulation in an hour? At $7.25 an hour?