First GHS compliance deadline has passed; expect OSHA to check for training

By December 1 of this year, employers should have trained employees on the new safety data sheet format and label elements under the revised HazCom Standard (HCS).

Why is the HCS revision important for employers? Every year, a list of the top 10 most frequently cited OSHA standards is released; and each year, the HCS makes the top five.

It has been estimated by OSHA that more than 650,000 hazardous chemical products are in use in the US. However, OSHA currently regulates exposure to approximately 400 substances. OSHA will never have the resources to address all chemicals this way, or even all significant chemicals; thus, the HCS covers them in general.

On March 26, 2012, OSHA published final revisions of the HCS in the Federal Register, aligning it with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). According to OSHA, there are many benefits associated with incorporating GHS into the HCS Standard, which applies to more than 43 million workers who produce or handle hazardous chemicals in more than 5 million U.S. workplaces.

Under the revised standard, the first compliance date was Dec. 1, 2013. All employees must now be trained on the use of new label elements and safety data sheets (SDS). Training on label elements should include information on:

  • product identifier
  • signal word
  • pictogram
  • hazard statement(s)
  • precautionary statement(s)
  • name, address and phone number of the chemical manufacturer, distributor or importer

Training on SDS must include information on:

  • the standardized 16-section format and the type of information found in each section
  • how information on the label is related to the SDS

Although the training date has passed, continuing awareness is essential in all affected enterprises. From history, we know that OSHA inspectors are going to focus on HCS compliance – even more so now that the standard has undergone such a dramatic change. We can expect OSHA to spend some time addressing these issues in enforcement inspections to help spread the word about the new requirements.

Additional compliance deadlines are approaching. If the HCS applies to your workplace, I encourage you to use available resources to stay up to date, including review of the revised standard and using OSHA “quickcards” on safety data sheets, labels, and pictograms. Random inspections are just that – you never know when one might occur.

For everything you need to know to prepare employees for the GHS implementation, including compliance deadlines, view UL’s white paper on The Globally Harmonized System of Classification and Labeling of Chemicals.