The HCS 2012 does not require employers to contact the manufacturers, importers, or distributors for SDSs for products they have not recently received. An employer that is maintaining an MSDS for a product not recently received would be considered to be compliant with the HCS 2012. The employer requirements of the HCS have not changed in that regard; employers are required to maintain MSDSs and SDSs that are received by manufacturers and distributors but they are not required to request or create SDSs in order to be in compliance.
For any shipment of chemicals after June 1, 2015, an SDS in the required 16-section format must be provided, and when a new SDS is received, it must be maintained. Additionally, companies are not required to send new SDSs to previous customers who may still have the product in inventory and new SDSs do not have to be provided for chemicals no longer produced.
Need more information? Call Cornerstone for assistance with HCS 2012.