Chemical Safety

What’s Next in GHS Compliance?

Date First Published on SafetySmart Compliance: December 19th, 2013

Topics: GHS Transition | HazCom |

he first GHS compliance deadline has come and gone—the requirement to provide GHS training to workers by December 1, 2013. But more tasks lie ahead. Here’s the timetable you should operate by to ensure compliance with GHS by the full compliance D-Day of June 1, 2016.

Deadline: Immediately

Initial GHS training of workers exposed to hazardous chemicals should be done by now. But continuing GHS training requirements should now be a permanent part of your safety program, including providing:

• Initial GHS training for a worker who’s not currently exposed to hazardous chemicals but who’s assigned to new jobs that involve exposure to hazardous substances before the job starts;

• New or re-training to previously trained workers whenever new chemical hazards for which they haven’t already been trained are introduced to their work areas; and

• Hazcom training and GHS training for any worker upon assignment to non-routine tasks involving exposure.

Deadline: June 1, 2016

Between now and June 1, 2016, containers of hazardous chemicals must have either Hazcom workplace labels or GHS labels. On June 1, 2016, all labels must be GHS labels. There are 2 ways to get the right label:

• Prepare it yourself; or

• Get it from the manufacturer, importer or distributor who supplied the product to you.

Deadline: June 1, 2016

As with labels, from now until June 1, 2016, any products classified as hazardous that you use, handle or store at your workplace will require either an old school MSDS or a newfangled SDS. After June 1, 2016, only an SDS will do. Although you can prepare it yourself, most employers get their MSDS/SDSs from the manufacturer, importer or distributor who supplied the product to them.

Deadline: June 1, 2016

As under Hazcom, once GHS rolls around, all employers will need to have a hazardous chemical inventory, i.e., a list of the controlled products they use, handle or store at their workplace. By June 1, 2015, chemical manufacturers need to reclassify their products using new GHS criteria. Result: Your current inventory will become obsolete.

What To Do:   You can rely on your current inventory through June 1, 2015. But then you’ll need to start re-doing your inventory so that each hazardous product on the list reflects its accurate re-classification status. You might even have to add new products to the inventory that weren’t classified as hazardous before but are re-classified as hazardous under the new GHS criteria.

Deadline: June 1, 2016

Hazcom requires employers to develop a written Hazard Communication Program (HCP) for their workplace. You’ll have to revise your current HCP to reflect changes to Hazcom made by GHS by:

• Attaching the revised hazardous chemical inventory to the HCP;
• Ensuring the HCP section on labels is consistent with GHS label requirements; and
• Ensuring the MSDS section is consistent with SDS requirements (and that references to “MSDS” are changed to “SDS”).

Deadline: June 1, 2016

The final step in GHS compliance is to adjust other hazardous chemical safety measures indirectly affected by GHS, including:

• Re-wording of warning signs under Standards for the more than two dozen specific hazardous substances for which warning signs are required, including asbestos, lead, acrylonitrile, formaldehyde, etc.
• Re-wording the chemical-specific warning labels for containers of those same specific substances for which warning signs are required; and
• Revising the labels required for containers of  dangerous welding and cutting chemicals.

Key Dates & Deadlines

DATE	SIGNIFICANCE	WHAT EMPLOYERS(1) MUST DO
June 1, 2015	Deadline for chemical manufacturers, importers & distributors to reclassify & prepare GHS-compliant SDSs	Nothing
Dec. 1, 2015	Deadline for chemical manufacturers, importers & distributors to meet GHS label requirements	Nothing
June 1, 2016	Deadline for updating your  Hazcom program to comply with GHS	Make sure each hazardous chemical has proper GHS label Make sure each hazardous chemical has proper SDS Provide any additional training employees need to follow your updated Hazcom program