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

The instructor clearly enjoys his job and transmits that enthusiasm. He made a dry subject very interesting and fun.

Teresa Arellanes

EHS Manager

The course was very well structured and covered the material in a clear, concise manner.

Ian Martinez

Hazmat Shipping Professional

I have over 26 years of environmental compliance experience, and it has been some time since I have attended an environmental regulations workshop. I attended this course as preparation for EHS Audits for my six plants, and it was exactly what I was looking for.

Frank Sizemore

Director of Regulatory Affairs

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

David Hertvik

Vice President

Excellent class, super instructor, very easy to follow. No rushing through material. Would like to take his class again.

Lawrence Patterson

EH&S Facility Maintenance & Security Manager

Lion courses always set the bar for content, reference, and practical application. Membership and access to the experts is an added bonus.

John Brown, CSP

Director of Safety & Env Affairs

The instructor was excellent. They knew all of the material without having to read from a notepad or computer.

Gary Hartzell

Warehouse Supervisor

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

Michele Irmen

Sr. Environmental Engineer

The instructor was energetic and made learning fun compared to dry instructors from other training providers.

Andy D’Amato

International Trade Compliance Manager

I really enjoy your workshops. Thank you for such a great program and all the help Lion has provided me over the years!

George Chatman

Hazardous Material Pharmacy Technician

Download Our Latest Whitepaper

In-flight hazmat incidents can be disastrous. This guide gives 5 tips for first-time air shippers to consider before offering dangerous goods for transportation on passenger or cargo aircraft.

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.