The December 1, 2013 OSHA’s GHS (Globally Harmonized System) training deadline has come and gone. Assuming you met this deadline and so are in compliance with the requirement to “train employees on the new label elements and safety data sheet (SDS) format,” you’re probably wondering what’s next! So let’s get to it.
What to Get Ready For
As an employer, you should be aware of the next three deadlines for the revised Hazard Communication Standard (HCS): June 1, 2015; December 1, 2015; and June 1, 2016.
Let’s look at each in more detail.
June 1, 2015: Full Compliance With One Labeling Exception for Chemical Distributors
Employers (that’s you) and chemical manufacturers, importers, and distributors must be in full compliance with the new Hazard Communication 2012 regulation with ONE exception—distributors can continue to ship containers that have old labels that are not compliant with the GHS labeling requirements for another six months.
The two years between the December 1, 2013 training deadline and this December 1, 2015 deadline is necessary for two reasons. First, since other countries, especially Canada and the EU, have already switched to GHS-alignment, American workers may start seeing GHS labels and SDSs (and so early training was necessary). And second, the staggered effective dates provide employers, distributors, and chemical companies a grace period to switch physical equipment/forms to GHS.
If you need a refresher on labeling and the new GHS graphics, check out my Guide to Updated GHS Standards in Canada, Europe, and the US.
December 1, 2015: Six-Month Labeling Exception for Chemical Distributors Expires
Chemical distributors can only ship chemical containers with GHS-compliant labels. Contact your distributor if you continue receiving shipments with outdated labels past this date. A GHS-compliant label is shown immediately below, if you need a reminder of what these look like.
June 1, 2016: Employers Update Alternative Workplace Labels, Hazard Communication Programs, and Provide Additional Training as Necessary
Employers must “update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards.” This is the final effective date for the transition to Hazard Communication 2012 and for full GHS compliance.
Conclusion–Get Going Now
Don’t get caught in violation of OSHA’s new GHS standards. Training is available and there’s still plenty of time to transition your safety data sheets and labels. But don’t put it off until 2016; get ahead of the game and update your company’s standards now.