June 21, 2013 | The United States Occupational Health and Safety Administration (OSHA) has updated its Hazard Communication Standard to comply with standards set forth by the United Nations. This change will cause many to adapt to new regulations and ways of marking, labeling, and shipping their goods in both interstate commerce and internationally. One of the most notable changes is the conversion of Material Safety Data Sheets to Safety Data Sheets. We covered this topic in our newsletter here at TCA. This new standard brings about many deadlines. We have answered a few questions to provide more information on the new Hazard Communication System.
Q: When does my GHS training need to be completed?
A: All training for the new HCS must be completed by December 1, 2013. This training is used to prepare employees and protect them from hazards, implement procedures, and teach the proper labeling requirements for packaging and shipping purposes.
Q: When do manufacturers and suppliers need to start providing the new SDS?
A: Manufacturers are already beginning to provide SDS information. In addition to this, when a chemical manufacturer, supplier, or employer is aware of new information required for an SDS, they must be listed on the labels. Any significant information regarding the hazards of chemicals should be added to the SDS within three months of the information being shared. When labeling the chemicals, all responsible parties should make the appropriate changes to their labels within six months of becoming aware of new information. One of the most notable changes in the SDS is that most of the content will not be changing; however, some wording and the order of the sections have changed. The words “should” and “may” are no longer used. Instead, the word “shall” is to be used.
Q: What are some of the key dates for implementation for the new HCS?
A: In addition to the December 1, 2013 training completion, there are a few other dates to keep in mind. While these dates may seem distant, it is important to keep in mind that many affected companies are already beginning to abide by the new standard. By June 1, 2015 all chemical manufacturers, distributors, importers, and employers must comply with the modified provisions of the Final Rule. By December 1, 2015 container shipments must utilize the GHS label. By June 1, 2016 all employers must update alternative workplace labeling and hazard communication programs.