Q. What are the OSHA compliance deadlines for the revised Hazard Communicaiton Standard?
A. Employee training should have been completed by Dec. 1, 2013 to help ensure all affected employees understand the new label and Safety Data Sheets (SDS) formats. Training remains a top priority.
Chemical manufacturers, importers and distributors were required to comply with the SDS and labeling provisions by June 1, 2015. Distributors then had until Dec. 1, 2015 to comply with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) labeling requirements for shipped containers. In anticipation of SDS and labeling deadline issues, OSHA sent a Feb. 9, 2015 memo directed specifically at chemical mixers who may miss the deadline due to upstream supplier delays. OSHA stated that it might not cite chemical mixture manufacturers and distributors who failed to meet the deadline provided they could show “reasonable diligence” and made a “good faith” effort to comply. Extensions of up to six months on an inspection-by-inspection basis were proposed to those who exercised reasonable diligence and good faith to obtain the required classification and SDS information from their raw material suppliers. If the situation falls within the categories in the memorandum, distributors will be allowed to ship chemicals labeled with old Hazard Communication Standard compliant labels until Dec. 1, 2017.
Employers have until June 1, 2016 to update their written hazard communication program, any alternate workplace labeling and provide additional employee training for newly identified physical or health hazards.
More Frequently Asked Questions
Under HazCom 1994, labels were performance-based; chemical manufacturers and distributors decided what to put on them. OSHA then determined if the labels were compliant based on how they performed in the workplace. Under HazCom 2012, OSHA prescribes label information based on six standardized elements:
1. Product identifier: Same identifier found on safety data sheet
2. Supplier information: Name, address and phone number of responsible party
3. Pictogram(s): Black hazard symbol on white background with red diamond border
4. Signal word: Must use either “Danger” or “Warning,” depending upon hazards
5. Hazard statement(s): Declarative statement regarding nature or degree of hazard
6. Precautionary statement(s): Descriptions of appropriate prevention, storage, response and spill measures
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