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Final GHS Compliance Deadline - June 1, 2016

Final GHS Compliance Date - June 1, 2016
The final milestone for the revised OSHA Hazard Communication Standard (HCS) is June 1, 2016.  As of this date employers are required to be fully compliant with the Global Harmonized System (GHS), including updating workplace labeling procedures, updating hazard communication programs as necessary and providing employees with training for newly identified physical or health hazards, new labeling procedures and understanding new Safety Data Sheets (SDSs).
Back up, give me some history...
In March of 2012, OSHA adopted the GHS system of classification and labeling of chemicals as a revision of the HCS.  GHS was adopted to improve the safety and health of workers through more effective communications on chemical hazards.  In 2013 OSHA outlined a number of target dates to facilitate the transition, with the final date approaching on June 1, 2016.  The adoption of GHS, brings several changes to the HCS including:
  • Hazard classification: The definitions of hazards were changed to provide specific criteria for classification of health and physical hazards, as well as classification of mixtures. These specific criteria will help to ensure that evaluations of hazardous effects are consistent across manufacturers, and that labels and SDSs are more accurate as a result.
  • Labels: Chemical manufacturers and importers are now required to provide a label that includes a harmonized signal word, pictogram, and hazard statement for each hazard class and category. Precautionary statements must also be provided.
  • Safety Data Sheets: SDSs now must have a standardized 16-section format.
  • Information and Training: Employers are required to train workers on the new label elements, and SDS format to facilitate recognition and understanding. 
 To be sure you are fully compliant; here are a few important steps you can take:
  1. Perform a chemical inventory - to confirm that all chemical containers are labeled properly in accordance with new requirements.
  2. Talk to your suppliers - to confirm that all chemicals coming into your facility are labeled in accordance with GHS. 
  3. Update your SDS library - to make certain all SDSs are available and stored in a location easily accessible to all employees.  This can be handled on-line as long as all employees have full access at all times.
  4. Train employees on GHS - to ensure that all employees are up-to-date on new GHS formats for labels and SDSs.  Training must be done initially, whenever a new hazard is introduced, or when workers change jobs and face potential exposures.  Annual update training is highly recommended.
  5. Update your Hazard Communication Policy - to be in compliance with the revised HCS.
Garden State Environmental, Inc. (GSE) has a team of expert compliance and training professionals available to guide employers through this process.  If you need assistance with any of the tasks above or have any questions, please contact us at 201-652-1119.