The first GHS deadline has passed. By December 1, 2013, all affected employers were required to train their employees on GHS labels and Safety Data Sheets (SDSs). If you have employees subject to GHS who have not been trained on these new elements, you need to get them trained as soon as possible.
Assuming your employees have been properly trained, what should you be looking out for now?
Upcoming Deadlines and Transition Period
The Globally Harmonized System of Classification and Labeling of Chemicals (GHS) is a systematic approach to:
Defining and classifying hazards of chemicals in the workplace and elsewhere, and
Communicating health and safety information on labels and SDSs.
The Occupational Safety and Health Administration (OSHA) incorporated GHS requirements to its Hazard Communication (HazCom) Standard on March 26, 2012. However, OSHA instituted a transition period, so that employers could have the appropriate amount of time to be in compliance with the new rules.
OSHA set the training deadline mentioned above first to prepare employees for what to expect in the upcoming months. With the exception of distributers, all facilities must implement new classification criteria, labels, and Safety Data Sheets by June 1, 2015. Distributors can ship products using the pre-GHS HazCom Standard until December 1, 2015.
Employers should not wait until the last minute to get into full conformance with GHS requirements. It will take some time to update all the hazard labels and SDSs in the workplace. Affected facilities should start as soon as possible, or they may find themselves out of compliance when the standard becomes mandatory.
What Can I Do During the Transition Period?
Until June 1, 2015, employers have a few options:
Employers can follow the old HazCom Standard, meaning that they are not required to have any GHS elements in the workplace yet. It is still legal to have old Material Safety Data Sheets (MSDSs) and labels. However, this is probably not the most prudent option.
Employers can completely transition over to the new rules, which include all new GHS elements. In a perfect world, everything is already transitioned, so employees do not have to deal with more changes and have only one standard to follow in the workplace. However, most companies are not this far along yet.
Finally, employers can follow a mixture of old HazCom and new GHS Standards. At this stage, this is the most likely scenario for most companies, and most workplaces probably utilize a mix of hazard communication. However, facilities need be very careful if they are in this phase, since employees can become confused by the different types of communication. This could require extra training to protect these employees.
Lion will present the last scheduled Preparing for OSHA’s New GHS Rule Webinar on March 4, from 1-3 p.m. ET. This live, instructor-led webinar is designed to help you prepare for a seamless transition to the revised HazCom Standard (HCS). Discover how new hazard classification, labeling, and SDS elements will affect your operations and what you must do to comply with the latest rules before the looming deadlines. For GHS training that’s available 24/7, EHS managers and supervisors can take the Managing Hazard Communication Online Course. For employees who need update training on new labeling and SDS elements, Lion offers the Hazard Communication Online Course, designed to satisfy OSHA’s HazCom training requirements (29 CFR 1910.1200(h)).