OSHA GHS Update – The June 1 Deadline

OSHA-compliant label

label example from OSHA Brief 3636

Are you in compliance with the OSHA Hazard Communication Standard, as revised to incorporate the Globally Harmonized System of Classification and Labeling of Chemicals (GHS)?

June 1, 2015, is an important deadline to meet the revised requirements. By this date, if your operation manufacture, import or distribute chemicals, you must:

  • identify hazards associated with the chemicals you manufacture, import or distribute, using the new “hazard classification” system that replaces the previous hazard determination;
  • properly label all hazardous chemicals shipped with specified label elements including signal word, pictograms, hazard statements and precautionary statements (see example above);
  • prepare and distribute with chemical shipments Safety Data Sheets that comply with the new 16-section format (replacing the former “Material Safety Data Sheet” or MSDS).

OSHA has signaled some leniency with regard to enforcement, particularly with respect to downstream manufacturers and distributors that may have difficulty obtaining hazard data on mixture ingredients from upstream suppliers.

HazCom GHS Training Slide - Title

Click on the image for our OSHA GHS training program

A few variances from the June 1 deadline may apply. The rule allows distributors to continue to use older, non-compliant labels (though compliant with the previous version of the Hazard Communication Standard, of course) on existing stocks until December 1, 2015. And appropriate revisions to alternative workplace labeling and to Hazard Communication Programs at the workplace where the shipped hazardous chemicals are received, handled and used are not due until June 1, 2016.

For more information or assistance, please contact T. Cozzie Consulting.