Sarah Lindsey, Staff Scientist at Schneider Risk Management
SRM & Associates LLC.
In 2012, OSHA updated its Hazard Communication regulation (29 CFR 1910.1200) to align with the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS), Revision 3. Some deadlines have already come and gone, and there are two deadlines left that you may need to be aware of: Chemical Distributors have until December 1, 2015, to update and ship all products under the new labeling requirements, and Chemical Users / Employers have until June 1, 2016 to finalize labeling and plans.
Chemical Users / Employers – By December 1, 2013, Employers were required to complete personnel training on the new labels and Safety Data Sheets (SDS). Employers must update their written Hazard Communication Plan and alternate workplace labeling by June 1, 2016. Employers will continue to be responsible for training their employees on any new hazards in the workplace.
Manufactures should have already started distributing updated SDS’s and using appropriate labels. If Users have not received updated SDSs, Users should request them from Producers.
Manufacturers, Distributors and Importers – Starting June 1, 2015, Manufactures, Importers and Distributors are required to comply with all provisions of HazCom 2012, with one exception. Distributors can continue to ship products under the old system until December 1, 2015. This means that producers are already required to be using the new Hazard Classification System, but Distributors still have some time to move leftover stock that still has old labels on the containers.
It is important to note that OSHA commented that most of the questions surrounding the GHS changes are about older requirements, not the new provisions. As the transition period comes to a close, it presents a great opportunity to perform an audit on your company’s Hazard Communication Plan. You can determine whether you are meeting both the new provisions and older requirements.
ResourcesHere are a few links to get you going:
As always, feel free to contact us if you have any further questions.