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GHS-HAZCOM Labeling Compliance: 6/1/16

New GHS Pictogram 2016

GHS-HAZCOM can be puzzling; another big piece is about to be dropped into place.

GHS-HAZCOM Labeling Compliance: 6/1/16 for Globally Harmonized System (GHS) of Classification and Labeling of Chemicals, must be in place. If you are currently using the ANSI model, you’ll want to switch to GHS to be compliant.

What will the changes be? So, What is New for OSHA in 2016

The areas affected by the alignment include:

  1. Chemical hazard classification
  2. Labeling of chemicals
  3. Safety Data Sheets (SDS) which are replacing Material Safety Data Sheets (MSDS)
  4. Training of employees

Change is inevitable but essential. Employers must be proactive with compliance to avoid OSHA fines and citations, but more importantly to protect their most important assets – Employees health and safety.

Click Here for a fact sheet to find out exactly what OSHA will be looking for after June 1, 2016

To summarize: OSHA says, “Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards.” This final timeline requirement applies to employers, but what does it mean? Essentially, it means that employers must have workplace labeling and hazard communication programs up to date as necessary (this includes having all Material Safety Data Sheet-formatted documents replaced with the newer Safety Data Sheet-formatted documents). It also states that additional training must be conducted for newly identified physical or health hazards.

Fortunately, it is the final deadline which means once you make your updates, you will have completed the transition.

If you are thinking about delaying this project you might want to think again.  OH&S says about the Final June 1, deadline:

“OSHA stated that it might not cite manufacturers and distributors who fail to meet this deadline if they’ve shown “reasonable diligence” and made a “good faith” effort to comply. To make this determination, OSHA will review both oral and written communications between chemical manufacturers and their upstream suppliers of raw materials. OSHA also will factor in whether or not these efforts were made in a timely manner. To avoid a citation, non-compliant manufacturers and distributors will need to be able to tell an OSHA inspector when they do expect to be GHS compliant, with a specific timeline.

It’s important to remember though, that “reasonable diligence” and “good faith” protection won’t last forever. In a presentation before the Society for Chemical Hazard Communication (SCHC) spring meeting in March, representatives from OSHA clarified that chemical blenders and distributors seeking relief from the June 1, 2015, classification deadline because they have not received data from their upstream vendors might be out of luck if they haven’t already made documented attempts to obtain that information.”

Make sure your puzzle pieces are ready to fit in place by making a good faith effort towards compliance. Have a working plan in hand and provide excellent ongoing training to your employees will minimize the risk should OSHA come knocking.

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