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.

OSHA has adopted the Global Harmonized System and revised the Hazard Communication Standard (HCS) to reflect the changes. The Final Rule was published in the Federal Register on March 26, 2012. The Effective Date of the final rule is 60 days after the date of publication.

Employers – What to Do and When?

• Employers must train workers on the new label elements and Safety Data Sheet (SDS) format by December 1, 2013.
• Chemical manufacturers, importers, distributors, and employers must comply with all modified provisions of the final rule by June 1, 2015. However, distributors may ship products labeled by manufacturers under the old system until December 1, 2015.
• By June 1, 2016, employers must update alternative workplace labeling and hazard communication programs as necessary, and provide additional worker training for new identified physical and health hazards.
• During this transition period, all chemical manufacturers, importers, distributors, and employers may comply with either 29 CFR 1910.1200 (this final standard), or the current standard, or both.

Are you ready? If you need assistance with understanding the GHS requirements, training or other safety topics, contact Bill Schneider at (614) 505-1209.