With few exceptions, companies who fear OSHA do not need to fear them. Even if you are out of compliance, the fines are very reasonable. The one thing a business cannot do is report that they fixed a small citation when they did not. That raises the issue ten-fold. So will ignoring a request from OSHA or a legitimate customer representative over a safety or compliance issue.
June 1st was the deadline for manufacturers, distributors, and suppliers to have their Safety Data Sheets ready to distribute to their down line customers. It should not worry any of them that they need some extra time. In the case of funeral homes and embalming chemicals, the deadline for the funeral home that purchases these products is still another year out.
When a supplier is late on a compliance date, then fails to acknowledge letters or emails that request information on when their SDS list will be online, they stupidly move from a potential serious citation and very light penalty to a willful citation with five figure fines. Letters requesting the information do not have to be from a customer. All of this could be avoided with a reply saying we are not sure when it will be ready. We will let you know. How difficult is it to do this?
In the funeral industry, several suppliers fell short on having their list ready for online publishing. I do not see this as more than a temporary minor problem. Suppliers, you should trust me on this. When you do not meet a deadline, do not compound it by ignoring information requests. Don’t let a potential small citation for around $500 be transformed into a $30,000 penalty because you were too lazy to respond to an information request.
To the suppliers who were on time, great job on a really tough task. To those who were almost there and responded to my request, I know you are trying on a super tough project. Keep up the good effort. To those major suppliers that could not find the time or resources to respond to my emails, don’t expect my next letter to be addressed to you. I won’t put up with it and OSHA says I don’t have to put up with it. OSHA says you have to respond to every request when it is regarding a deadline you are missing. That is relevant to job safety and health.
When you don’t bother to even do that, it says so very much about your attitude towards OSHA, your attitude towards your customers, and your attitude toward companies which represent many of those funeral homes. You know who you are. I am not going to mention names. Just know what your compliance duties are. Your customers already do.