GHS Deadlines and Implementation Guide

 Effective Completion Date  Requirement(s)
  Who
 December 1, 2013  Train employees on the new label elements and SDS format.  Employers
 

June 1, 2015*

December 1, 2015

  

Comply with all modified provisions of this final rule, except:

Distributors may ship products labeled by manufacturers under the old system until December 1, 2015.

 Chemical manufacturers, importers, distributors and employers
 June 1, 2016  Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards.  Employers
 Transition Period  Comply with either 29 CFR 1910.1200 (this final standard), or the current standard, or both.  All chemical manufacturers, importers, distributors and employers

* This date coincides with the European Union implementation date for classification of mixtures.

What you need to do:

Chemical users:messageus

  • Continue to update safety data sheets when new ones become available from the manufacturer or online.
  • Provide training on the new label elements and update hazard communication programs if new hazards are identified in the workplace.

Chemical Producers:

  • Review hazard information for all chemicals produced or imported, classify chemicals according to the new classification criteria, update labels and safety data sheets, and distribute to customers.
  • Other U.S. Agencies have participated in developing and implementing the GHS. The GHS system is also going to be implemented globally.

Frequently Asked Questions About the June 1st GHS Deadline:

Q: What is the Globally Harmonized System?

A: The Globally Harmonized System (GHS) is a universal approach to hazard communication by providing uniform criteria for the classification of chemical hazards and a standardized method to label elements and safety data sheets. The GHS goal is to provide harmonized classification criteria for health, physical, and environmental hazards of chemicals.

Q: What is expected to be done by June 1, 2016?

A: Employers are responsible for obtaining all updated Safety Data Sheets, and updating alternative workplace labeling and the hazard communication program as necessary. They are also responsible for providing additional employee training for newly identified physical or health hazards.

Q: Is the manufacturer going to send me the new Safety Data Sheet (SDS) or am I required to obtain them myself?

A: It is the employer’s responsibility to obtain the new SDS. This information can be found on the manufacturer’s website or by contacting the manufacturer directly.

Q: What should I do if the manufacturer did not update the MSDS to the new SDS format?

A: If you still have a MSDS and need to obtain the new SDS, you should contact the manufacturer directly. If the manufacturer communicates that they have not yet made the transition, it is crucial to document your request to the manufacturer and ensure that you have the most up to date version of the MSDS on file. OSHA is primarily concerned that all MSDSs are converted to SDSs by the outlined effective date. If a MSDS has not been updated and diligent effort by the employer has been made and documented to obtain said updated SDS, then the ultimate responsibility falls on the manufacturer.

Questions?

Call a Lancaster Safety Consultant today at (724) 776-1003 or send us an email here.

Source: OSHA.gov