How Will GHS Affect My Current Hazcom Program?

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About The Expert

Glenn Demby is an OSHA attorney and editor-in-chief of SafetySmart Compliance

QUESTION
Under GHS, will employers still need to have a written hazcom program? If so, can I keep using my current program or will I have to change it?
ANSWER
Yes and yes.
EXPLANATION
Current Law: The current OSHA Hazcom standard (Sec. 1910.1200(e)) says employers must implement a written hazard communication program that includes, among other things, a description of the system used to comply with Hazcom MSDS and label requirements and deliver training and information to employees.
What the GHS Rule Says: OSHA’s final GHS Rule makes no substantive changes to Sec. 1910.1200(e). But it does change the label and MSDS—now referred to as SDS, or Safety Data Sheet—requirements.
What It Means to You: Practical effect on you:

  1. You’ll still need a written hazcom program at your workplace after GHS takes effect;
  1. The hazcom program will have to address the same things it does now; and
  1. You’ll have to update the label and MSDS/SDS sections of your program to comply with GHS. The deadline: June 1, 2016.

Caveat: The deadline to train employees about the new GHS labels and SDSs was Dec. 1, 2013, which was 2 years before those things actually have to be used.
How to Submit Questions
‘Got a question about GHS or any other aspect of OSHA compliance? Submit it to glennd@bongarde.com. You’re also invited to join Glenn for a webinar about GHS and other new OSHA rules in the pipeline for a 90 minute webinar at noon, Eastern, Thurs. April 5. Click here for more details.

 
 
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