Get a Head Start on GHS Compliance

From Hazcom to GHS

Date First Published on SafetySmart Compliance: March 26th, 2012
Topics: GHS Transition | HazCom |

March 26, 2012 – Now that OSHA finally issued the Final GHS Rule, you face the task of making the transition to GHS.  A key task in the transition will be to go through your current workplace Hazard Communication Program (HCP) and revising it to meet GHS requirements. Here’s what you have to do and when. Click here if you want more detail about a rule and what you must do to comply with it.

10 Ways GHS Will  and Won’t Impact Your  Current  Hazard Communication Program

WHAT YOU MUST DO NOW

WHAT YOU’LL HAVE TO DO UNDER GHS

DEADLINE

Implement written HCP at your workplace

Same

NA

Make HCP available upon request to employees, representatives & OSHA officials

Same

 

NA

Explain your labeling system in HCP

Same. Even though labels are changing, you can probably use the same system. But language in HCP must be in line with the new GHS label requirements.

June 15, 2016

Explain your MSDS system in HCP

Same. Even though MSDSs are changing to SDS, you can probably use the same system. But language in HCP must be in line with the new GHS requirements, e.g., refer to SDS rather than MSDS.

June 15, 2016

List in HCP hazardous chemical information & training you provide

Same. But you must provide GHS training to employees by Dec. 1, 2013 and revise HCP to reflect changes in training required by GHS.

  • Dec. 1, 2013: Deadline to train

  • June 1, 2016: Deadline to revise HCP

Include a list of hazardous chemicals in your HCP

Same. But you’ll have to revise your current inventory after chemicals are re-classified by manufacturers/importers by June 1, 2015

  • June 1, 2015: Deadline for re-classification
  • June 1, 2016: Deadline to revise your haz chem inventory

Explain in HCP how you warn employees about hazards of non-routine tasks.

Same

NA

Explain in HCP how you warn employees about chemical hazards in unmarked pipes in their work area

Same

NA

Explain in HCP how you give contractor employees access to MSDSs

Same. You can keep using the same MSDS access system but will need to make cosmetic changes to HCP for GHS, e.g., change “MSDS” to “SDS”

June 1, 2016

Explain in HCP how you notify contractor employees of precautionary measures

Same

NA

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