GHS Transition – Are You Ready?

The most important bit and primary OSHA requirement is employees are trained on the new label elements and Safety Data Sheet (SDS) format by December 1, 2013; while full compliance (adoption of the changes into written programs) and enforcement of the rule will begin in June 2015. Since many American and foreign chemical manufacturers have already begun to produce GHS-compliant labels and SDS’s, workplaces will soon begin receiving the new SDS chemical labels that are consistent with the GHS transition.  It is important to ensure that when employees begin to see the new labels and SDS’s in their workplaces, they will be familiar with them, understand how to use them and access the information effectively.

For those concerned, the following steps are a starting point to getting acquainted with the HazCom changes:

• Learn the Facts – OSHA GHS Resource
• Know Your Chemical Inventory – Organizations are already held to the standard of knowledge and awareness of the hazardous chemical they use and are present in the workplace.  If you are not doing this, stop reading and start now.
• Train Your Employees – All affected employees need to be trained on the changes to the Hazard Communication Program by December 1^st of this year.
• Update Your Written Programs – This requirement is effective June 1^st 2015; but that doesn’t mean you should wait on preparing your updated Hazard Communication written program material.

Included below is a list of important dates and the OSHA resource page for the GHS transition:

• December 1, 2013: Employers need to train employees on the new label elements and Safety Data Sheet (SDS) format.
• June 1, 2015: Chemical manufacturers, importers, distributors and employers must be in full compliance with all modified provisions of this final rule except: The distributor shall not ship containers labeled by the chemical manufacturer or importer unless it is a GHS label (Dec. 1, 2015).
• June 1, 2016: Employers must update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards.
• Transition Period to the effective completion dates noted above: Chemical manufacturers, importers, distributors and employers may comply with either 29 CFR 1910.1200 (the final standard), or the current standard, or both.