The first of the Globally Harmonized System (GHS) compliance dates are fast approaching. These compliance dates are listed below:
| Effective Completion Date |
Requirement(s) |
Who |
| December 1, 2013 | Train employees on the new label elements and safety data sheet (SDS) format. | Employers |
| June 1, 2015December 1, 2015
|
Compliance with all modified provisions of this final rule, except:
The Distributor shall not ship containers labeled by the chemical manufacturer or importer unless it is a GHS label. |
Chemical manufacturers, importers, distributors and employers |
| June 1, 2016 | Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards. | Employers |
| Transition period to the effective completion dates noted above | May comply with either 29 CFR 1910.1200 (the final standard), or the current standard, or both | Chemical manufacturers, importers, distributors, and employers |
Ref: https://www.osha.gov/dsg/hazcom/hazcom-faq.html#3
Conversations with local OSHA inspectors in Indiana and Michigan indicate that GHS is at the top of their list. This will be one of the first questions when they visit your facility. Whether they will fine you immediately during this transition period or not, we will wait to see. We believe OHSA will be lenient, but only for a little while. Our conversations indicate that even if all of the employees are not 100% trained, beginning the program is better than not at all.
Some useful websites for training are the OSHA GHS site along with the IOSHA site. The OSHA site has the GHS Manual, which describes in detail the reasoning behind the transition, the compliance dates along with various requirements for implementation at your company. This site will also explain the physical hazards, the health and environmental hazards and the interactions of these hazards. The Bridging Principal, an important concept in the GHS for classifying untested mixtures, is important to understand for chemical manufactures.
Hazard communication is the last section of the manual which describes the factors involved for development of the GHS communication tools. The labels, which depict the 9 different “pictograms,” are explained along with the precautionary statements. Lastly, the term Material Safety Data Sheet or MSDS has been shortened to Safety Data Sheet or SDS. The SDS format is comprised of 16 sections and manufactures are required to use this new format by June 1, 2015.
If you need help, DECA can assist. One method is to provide the onsite training for your employees and tailor it for your facility. The second is to provide a training kit through our partners at KHA (www.ghskit.com). Either way will ensure compliance with the December 1, 2013 deadline.
DECA can also assist with the organization and ensure the (M)SDS is up-to-date by implementing online data management of the SDS specifically for your company. This demo-site, DECA Demo, is an example of the site we can implement for your facility.
