ANSWER: 

This is actually good news, to a degree.  Your compliance responsibilities will be reduced because you’re not a manufacturer.  However, government agencies – federal, state, county, and local -  regulate EHS compliance by chemical hazards, processes, and human exposure to hazards in the workplace, rather than the nature of your business activity.  For instance, EPA’s SARA Title III (1986) established compliance requirements for manufacturers to begin by March of 1987 reflective of the previous calendar year.  Then, the same requirements, with very few exemptions, were established for NON-MANUFACTURERS to begin by March of 1988 (the very next year) for the previous calendar year. 

But also, please remember the regulatory umbrella phrase, “If you USE, STORE, PROCESS, PRODUCE, MANUFACTURE, DISTRIBUTE, OR IMPORT" a chemically-oriented product – as reflected in your facility’s Material Safety Data Sheets (MSDSs) – then you’re definitely accountable for many EPA, OSHA and DOT laws with further regulatory offshoots at the state, county and local levels.

Frankly, there are not many OSHA laws that will carry any compliance relief for non-manufacturers.  But true, the hazards will probably be less which, in turn, probably reduces your overall compliance responsibilities.  Generally speaking, almost any facility in which a chemical inventory is reflected in the company’s MSDSs can count on executing the necessary due diligence for, and satisfying compliance on at least 3 laws:  EPA SARA Title III/EPCRA, Sec. 301-312 (In California, satisfied as a part of Hazardous Materials Business Plan);   OSHA Hazard Communication Training;  and DOT Hazmat Employee Training.

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