The OSHA Hazard Communication Standard (HCS) has been aligned with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The GHS establishes specific criteria for classification of health and physical hazards, and mixtures, new requirements for labeling and a new format for safety data sheets (SDS).
WHAT ARE THE CHANGES AND WHEN DO THEY TAKE EFFECT?
The requirements and effective dates are shown below.
- December 1, 2013: Employers must train employees on the new labeling requirements and safety data sheet (SDS) format.
- June 1, 2015: Employers must revise the Hazard Communication (Hazcom) Program to meet the GHS.
- December 1, 2015: Chemical manufacturers, importers, and distributors must convert MSDS to the new SDS format. Chemical containers may not be shipped without a GHS label.
- June 1, 2016: Employers must update alternative workplace labeling and Hazcom Program, and provide employee training for newly identified physical or health hazards.
OSHA has stated that during the phase-in period, employers would be required to be in compliance with either the existing, new or a combination of both HSC. For example, OSHA recognizes that there will be a period of time where labels and SDS under both standards will be present in the workplace. This will be considered acceptable, and employers are not required to maintain two sets of labels and SDS for compliance purposes.
- Review the new HCS to become familiar with the changes (see links below).
- Watch for the new format in your incoming MSDS/SDS and container labels.
- Find out when your chemical suppliers plan on adopting the new requirements. You may want to ask them to do this all at once, so that you are not having to sporadically change all of your MSDS to SDS.
- Plan to train your employees by December 1, 2013 on the new HCS. Consider presenting the training early in 2013, given that your employees may be seeing SDS and new labeling soon.
- Plan to update your Hazcom Program in the 2013-2015 timeframe.
For More Information:
OSHA HCS Web Site: http://www.osha.gov/dsg/hazcom/index.html
EPS can assist you in addressing the HCS, including training programs and the other action items listed above.