Search

OSHA Memo Shows How GHS HazCom Will Be Enforced

Posted on 6/4/2015 by Roger Marks

Now that the June 1 deadline for GHS compliance has passed, chemical manufacturers and shippers nationwide are adjusting to new requirements under OSHA’s revised Hazard Communication Standard (HCS). OSHA inspectors will begin enforcing compliance with these revised rules during site audits, and it’s critical that employers understand what’s required and how to comply.

A memo issued to OSHA regional administrators on May 29 includes some important guidance on how these rules will be enforced in the US.

OSHA to Chemical Re-packagers, Blenders, Mixers: You ARE Manufacturers.

According to the new OSHA guidance, many businesses that repackage, blend, or mix hazardous chemicals consider themselves to be distributors, not manufacturers. OSHA clarifies that, under the HCS, these businesses are considered manufacturers. Therefore, the new GHS requirements do apply to them.
OSHA GHS Hazard communication label on chemical container

What If My Suppliers Haven’t Yet Provided New Information?

In order to classify a chemical product, manufacturers sometimes must rely on information provided by upstream suppliers. If a manufacturer has not received this information and can “demonstrate it has exercised reasonable diligence and made good-faith efforts to obtain and integrate” it, the manufacture may continue to use HCS 1994 labels. These good-faith efforts should include attempting to find hazard information from alternate sources (e.g., chemical registries). OSHA includes specific steps and recordkeeping practices required for businesses to prove they’ve made a “good-faith effort.”

Once manufacturers have received information to develop an updated Safety Data Sheet (SDS), they have six months to develop a GHS (HCS 2012)-compliant chemical label.

What Do I Do With Pre-packaged Stock?

Manufacturers can continue to ship downstream existing stock packaged before June 1, 2015, even if it is not GHS-compliant. Businesses are not required to re-label containers with GHS-compliant labels, but they must provide GHS labels and SDSs for each and every individual container shipped, unless they demonstrate inability to get a hold of the information despite the reasonable diligence and “good-faith” efforts described in the memo.

View the full OSHA memo at the Department of Labor website.

GHS Training for Managers and Employees

Make sure your employees are prepared to protect themselves under OSHA’s HCS with the Hazard Communication Online Course, updated to reflect the new GHS standards in effect as of June 1, 2015. For EHS managers who oversee their site’s GHS HazCom program, Lion offers the Managing Hazard Communication Online Course.

Tags: GHS, HazCom, new rules, osha, Safety Data Sheets

Find a Post

Compliance Archives

Lion - Quotes

Lion's course was superior to others I have taken in the past. Very clear in the presentation and the examples helped to explain the content presented.

George Bersik

Hazardous Waste Professional

The training was impressive. I am not a fan of online training but this was put together very well. I would recommend Lion to others.

Donnie James

Quality Manager

I used the IT support number available and my issue was resolved within a few minutes. I don't see anything that could have made it better.

Danny Province

EHS Professional

Very witty instructor, made the long times sitting bearable. One of the few training courses I can say I actually enjoyed.

John Hutchinson

Senior EHS Engineer

I was able to present my scenario to the instructor and worked thru the regulations together. In the past, I attended another training firm's classes. Now, I have no intention of leaving Lion!

Diana Joyner

Senior Environmental Engineer

The instructor took a rather drab set of topics and brought them to life with realistic real-life examples.

Tom Berndt

HSE Coordinator

Lion does a great job summarizing and communicating complicated EH&S-related regulations.

Michele Irmen

Sr. Environmental Engineer

Excellent job. Made what is very dry material interesting. Thoroughly explained all topics in easy-to-understand terms.

David Hertvik

Vice President

Course instructor was better prepared and presented better than other trainers. Course manual and references were easier to use as well.

Marty Brownfield

Hazardous Waste Professional

Lion's online training is more comprehensive, has better slides, and is a superior training experience than what I would get from other trainers.

Robert Brenner

District Environmental Manager

Download Our Latest Whitepaper

Knowing why TSDFs reject loads of hazardous waste—and the exact steps to follow if it happens—can reduce your anxiety and uncertainty about rejection.

Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.