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January-February 2024

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Derek needs 120 48"x40" stringer pallets next month. Adele L. Abrams is an attorney and safety professional who represents companies in litigation with OSHA and also provides safety training and consultation. The Law Office of Adele L. Abrams PC has three offices: Beltsville, MD; Denver, CO; and Charleton, WV. She may be reached at safety-law.com or 301-595-3520. ere is a lot of meat to most of these rules, particularly the new recordkeeping rule which was already finalized and takes effect January 1, 2024 (details covered in a previous column). Expected final changes to the Hazard Communication Standard—which are now at the Office of Management and Budget undergoing final review—will impact all employers, as new training on hazard classification systems will be needed, and distributors and wholesalers may also need to relabel products and palletized loads as well as transmit updated Safety Data Sheets to downstream customers. Another rule with broad impact will be the modifications to OSHA's Powered Industrial Truck (forklift) standards. New training and maintenance requirements will be embedded in design specification changes, and issues concerning fleet obsolescence remain. NWPCA previously submitted substantive comments on this forklift proposal. e sheer number of initiatives precludes a detailed review here, but we will address the new rules as they come down the OSHA chute during 2024. May your "interesting times" be healthy and safe in the coming year! "The new regulatory agenda released by the Occupational Safety and Health Administration (OSHA) in December 2023 reveals a push to get new rules completed in time to insulate them from potential rescission by the next Congress and president."

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