This is the second installment of a three part series on changes in chemical management. Part one, “OSHA Adopts GHS” outlined major changes OSHA recently made to its Hazard Communication Standard (HazCom or HCS) through its adoption of the United Nation’s Globally Harmonized System (GHS). (Find Part I here). The changes affect every employer with employees exposed to hazardous chemicals. This week focuses on helping employers meet the first compliance deadline, December 1, 2013.
Note: OSHA refers to the new HazCom Standard (post GHS alignment) as HazCom 2012. It refers to the old HazCom Standard (pre GHS alignment) as HazCom 1994. This article does the same.
A Time to Train
OSHA’s revised HazCom Standard has four key deadlines as detailed in Table 1:
|
Deadline |
Stakeholders |
Compliance Requirements |
|
Dec. 1, 2013 |
Employers |
Train employees on new labels elements and safety data sheet formats |
|
June 1, 2015 |
Chemical Manufacturers, Distributors, Employers |
Reclassify chemicals using adopted GHS criteria, update labels and safety data sheets |
|
Dec. 1, 2015 |
Distributors |
Cease shipping chemicals with manufacturer labels in the HazCom 1994 format |
|
June 1, 2016 |
Employers |
Update hazcom programs and secondary container labeling systems as necessary, train employees on newly identified hazards |
Table 1
The first deadline, December 1, 2013, is just weeks away and focuses on training employees who are exposed to hazardous chemicals in the workplace on important updates to safety data sheets and labels.
Some might question why OSHA wants employees trained on the changes a year and half before chemical manufacturers and distributors have to make them, and the answer is because OSHA wants employees familiar with new label elements and the new safety data sheet format before they encounter them in the workplace. There is nothing preventing chemical manufacturers or distributors from making the changes now and in fact, many safety data sheets and labels in the GHS style are already in the marketplace.
This first round of training is not intended to be comprehensive on all things HazCom. OSHA’s expectation is that employees have already been trained on HazCom in general and on the specific hazards of the chemicals to which they’re exposed. This first deadline is only about getting employees familiar with the basic label and safety data sheet changes; as such, OSHA believes this training can be done swiftly.