Almost There: Final GHS Deadline—June 1

Posted on 5/3/2016 by Lee Ann Coniglione

Can you believe it’s been four years since OSHA’s revised Hazard Communication Standard (HCS, or HazCom) took effect? Since May 2012, manufacturers, suppliers, and employers have contended with several implementation deadlines. If you work in the business of chemical manufacturing, distribution, import, or handling, by now you should be well versed in the workplace changes resulting from the revised 2012 Hazard Communication standard (HCS 2012).

The HCS 2012 revisions were the result of aligning the existing OSHA Hazard Communication standard (HCS 1994) with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The GHS alignment resulted in many changes to the HCS itself. OSHA provided a timetable for implementation to help affected employers make necessary changes.

Timeline of GHS Hazard Communication Deadlines

The first GHS deadline was December 1, 2013. By this date, employers were required to train employees on how to read the newly updated Safety Data Sheet (SDS) format and new GHS hazard labels. Since December 2013, two other GHS deadlines have passed. Now, we approach the final deadline.

By June 1, 2016, employers are expected to have completed the following tasks:
  • Incorporate updates into their written hazard communication program, as necessary;
  • Make updates to any alternative labeling practices implemented in the workplace, as necessary; and
  • Provide additional employee training for newly recognized workplace hazards (i.e., physical and/or health hazards).
GHS Emphasis on Hazard Classification

One of the most significant departures from OSHA’s previous HazCom Standard is the GHS’s focus on hazard classification. Due in part to the shift from hazard determination to hazard classification, numerous changes trickled down throughout the HCS, including how certain terms were defined, the addition of new terms, and the deletion of “obsolete” ones.

Another big change to the HazCom Standard is the transition to a criteria-based classification process for hazardous chemicals. Under GHS HazCom, hazard classes fall under one of two broad headings: physical hazards and health hazards. Some example GHS hazard classes include carcinogenicity, skin corrosion/irritation, aspiration, corrosive to metals, flammable solids, and pyrophoric gases.

Within each hazard class are hazard categories that represent varying degrees of severity in terms of physical and health outcomes. Categories are separated from one another by cut-off values, or measurable criteria. Some hazard classes have only one hazard category (e.g., pyrophoric solids), while others comprise multiple hazard categories.

The upshot of this GHS hazard classification discussion is that employers must be aware of the new rules for classifying hazardous chemicals. This means evaluating current chemical inventories based on the revised classification criteria. It’s possible that chemicals formerly considered non-hazardous under the old HazCom regulations are now considered hazardous under GHS.

Workplace Labeling

Once employers have established a revised list of in-house chemical inventories, the next step is labeling workplace containers. Over the years, many employers have used alternative labels for in-house containers, guided by the popular NFPA or HMIS rating systems. While OSHA continues to allow the use of such systems, any alternate means of labeling must provide the product identifier and a minimum amount of information regarding the chemical’s hazards.

In addition, containers may not feature any information on the container that differs or conflicts with the requirements of the GHS HazCom Standard. Lastly, if an employer does use an alternative in-house labeling method, employees must be trained on how to use that system and have access to all hazard information.

Update GHS Training for Changing Chemical Classifications

Any time the classification of a chemical changes, the employer must re-train all affected employees. This training must cover relevant changes, which may include the required label elements (e.g., pictograms, hazards statements, signal words) or changes to a particular section of the Safety Data Sheet. Whenever a workplace change affects the use or handling of hazardous chemicals, employers must update their written hazard communication program accordingly.

The Final GHS Deadline is Coming: Be Ready On June 1!

Be confident you know what it takes to update your site's hazard communication plan to align with OSHA's adopted GHS requirements. Learn what's required in a plan and how to get your team prepared with the Managing Hazard Communication Online Course. Enroll now to get six months of Lion Membership for fast answers to your questions, exclusive resources, rule updates, and discounts on select Lion training events.

To help employees recognize and use new GHS hazard labels and Safety Data Sheets, the Hazard Communication Online Course is available for $49 per student. Workers can access the course 24/7 from home or work, and

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