Safety consultants and OSHA area offices are receiving calls about the looming June 1, 2015 date when OSHA’s Hazard Communication standard undergoes another in a series of scheduled changes to align with a Globally Harmonized System (GHS). If you are one of most employers, you may be wondering if this next change applies to you. The short answer is, “No, but yes.”

OSHA’s 2012 HAZCOM standard is in the midst of phased-in implementation, and the next phase of implementation occurs on June 1, 2015 -the date in which manufacturers of chemicals and products requiring a Safety Data Sheet (formerly known as Material Safety Data Sheet) must be in full compliance with HAZCOM GHS. Manufacturers of chemical products, not the employers who use them, must be in full compliance with this new standard by June 1 of this year.

However, there are two things about which all employers must know regarding June 1, 2015 or face the possibility of OSHA enforcement action:

1. Employers must maintain the most recent version of the MSDS or SDS the manufacturer supplies. If the employer receives a new Safety Data Sheet for a chemical, the employer is expected to maintain that SDS according to 29 CFR 1910.1200. In brief, the employer must ensure all SDSs (and when SDSs are not available, MSDSs) are the latest versions in their SDS file available for employee review.
2. All employers who use hazardous chemicals must still comply with a portion of the HAZCOM standard deadline of December 2013 for training employees. Employers should have trained employees on the new label elements and Safety Data Sheet format associated with the new standard by now. If this hasn’t occurred, employees should be trained immediately. An OSHA Fact Sheet containing minimum training requirements is available as a guide.

All employers must fully comply with the Hazard Communication Standard by June 1, 2016, so there is time to become fully immersed in the impending changes by then. However, for current obligations of SDS maintenance and employee training, employers need to address these obligations as soon as possible or risk potentially expensive enforcement action from OSHA.

There are 4 key compliance dates related to OSHA’s phased-in adoption of GHS:

• December 1, 2013 Employers must train employees how to read GHS formatted labels and safety data sheets.

• June 1, 2015 Chemical manufacturers and distributors must complete hazard reclassification and produce GHS styled labels and safety data sheets. Distributors get an additional 6 months to complete shipments of old inventory.

• December 1, 2015 Distributors must comply fully with Hazard Communication Standard requirements (Grace period for shipments of old inventory ends).

• June 1, 2016 Employers must be in full compliance with revised Hazard Communication Standard, including complete training of employees on new hazards and/or revisions to the workplace hazard communication program.

Safety First Consulting helps businesses identify OSHA compliance issues in their workplaces, manage their safety programs, and we become accountable for the results. In addition to offering custom written safety programs for companies, Safety First Consulting provides required safety training, industrial hygiene sampling, noise sampling, and workplace inspections.

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