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OSHA has enhanced its Hazard Communica-tion Standard (HCS) 29 CFR 1910.1200 to align with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS). GHS is primarily concerned with the classification of hazardous chemicals and the communication of hazards related to those chemicals to users of the products via warning labels and Safety Data Sheets (SDS). Currently over 65 countries have or are in the process of adopting GHS. OSHA is calling the revised standard “HazCom 2012” and it went into effect in the U.S. May 25, 2012 affecting over 5 million employers and 40 million work-ers. Two significant changes contained in the revised standard require the use of new label-ing elements and a standardized format for SDSs, formerly known as, Material Safety Data Sheets (MSDSs).

GHS Compliance Deadlines

The first deadline is December 1, 2013. By this date, employers must train employees on GHS (how to read and understand new labels and SDSs), manage the influx of new SDS’s which will include replacing their entire MSDS library, and be ready to produce GHS compliant workplace labels. To prepare, employers should begin educating themselves on the changes as they will want to train employees well before the December 1, 2013 deadline. Existing fines and penalties for non-compliance with the HCS will extend to the new GHS alignment. This means that HCS violations, which already rank #3 on OSHA’s Top Ten Violations List, could see even more action.

The next compliance deadline is June 1, 2015, the date by which chemical manufacturers and distributors must reclassify their chemicals according to GHS guidelines and produce GHS formatted safety data sheets and labels.

The final deadline is June 16, 2016, the date by which employers must be fully compliant with GHS. This means all training of employees on any new hazards that have been identified in the reclassifying of chemicals by the manufacturers and distributors. It also means workplace labeling and workplace hazard programs must be up-to-date.