It started out as a noble idea to make the world a safer place. What if everywhere you went in the world, hazardous chemical compounds were labeled according to a universal template so that workers handling those materials would never misinterpret a label because it was formatted differently?

This dream of a globally harmonized system came one step closer to reality in 2012 when the U.S. Occupational Safety and Health Administration (OSHA) mandated a change in the enforceable standards known as HazCom, or Hazard Communication Standard 2012, or HCS. Thus began a gradual transition in the U.S. from the old provincial standards towards the Globally Harmonized System (GHS) that will continue to be incrementally deployed until it is officially complete by June of 2016.

Any undertaking of this magnitude is going to produce a lot of questions and a good deal of anxiety for businesses who have a healthy fear of regulatory agencies. Adding fuel to the anxiety is the confusing array of deadlines stretching from here to 2017. The good news for most HUB clients is there are really only two deadlines that specifically apply to you. Most of the deadlines are directed at the importers, producers and distributors of the chemical products and not at the end user, who are referred to in the standard as an employer.

EMPLOYERS’ RESPONSIBILITIES:

1. They must train their employees to recognize and understand GHS compliant labels with all their elements, including pictograms, signal words, etc.
2. They must familiarize their employees with the new “Safety Data Sheet” format with its 16 sections and how to get needed information from the sheet to advise on proper use and recommended treatment in case of exposure or accident. These SDS replace MSDS.
3. As with earlier renditions of the HazCom standard, employers must have a written policy that outlines the company’s safety procedures and prescribed approach to dealing with the kinds of hazardous chemicals and products used by employees in their duties at the company. They must also collect Safety Data Sheets of all hazardous materials in use in their plant. All of this must be published in a form that is accessible at all times to all affected workers.
4. If you use bulk chemicals and transfer them into smaller containers at your jobsite or place of business, certain rules apply regarding the labeling of those containers. See references below for more information.

DEADLINES:

There are only two deadlines that matter to end users: NOW, and June. 1, 2016.

1. NOW: All the employer responsibilities mentioned above related to training are already enforceable. The requirement mentioned above to publish a written usage policy for employees and to collect safety data sheets has been in force for years. If you have been compliant in the past, all that is required is to revise your policy reflecting the GHS training requirements and update MSDS with SDS as they become available.
2. June 1, 2016: This end date is important for employers because enforcement will become more serious once the program is fully implemented. During the transition period, enforcement is going to hinge on whether you are making a “good faith effort” to comply in an environment where entities upstream of you may not have provided you with the elements that you need to be fully compliant.

The deadline for manufacturers to convert to SDS from MSDS has already passed as of June 30, 2015. Technically it is their responsibility to include any new or revised SDS with their next shipment to their downstream users. Even though the burden rests on them, it shows good faith to periodically review your library of safety sheets and request the missing SDS you may not have received.

WHAT HUB IS DOING TO HELP YOU:

1. We have added SDS sheets to products on our website. They are found on each product page.
2. We have many products available to assist your compliance efforts, including SDS binders and “need to know” stations that you can place on your shop floor where employees can access the information the HazCom requires.
3. We can answer questions you may have regarding HazCom or point you in the direction of someone who can.

ADDITIONAL RESOURCES:

Frequently asked questions and details about on-site labeling of secondary containers: http://tinyurl.com/ocjssao
OSHA HazCom landing page: https://www.osha.gov/dsg/hazcom/index.html

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