ELR Citation: ELR 20231
No(s). 87-4143 (2d Cir. Dec 30, 1987)

The court holds that the Occupational Safety and Health Administration's amendments to its Hazard Communication Standard were not "promulgated" within the meaning of the Occupational Safety and Health Act until they were published in the Federal Register. The use of both "issued" and "promulgated" i...