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:
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:
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:
Deadline: June 1, 2016
The final step in GHS compliance is to adjust other hazardous chemical safety measures indirectly affected by GHS, including:
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 |
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