It’s time to tie up loose ends from 2014 and get EHS programs prepped for the new year. For businesses covered by OSHA’s Hazard Communication Standard (HazCom) that means preparing for two major GHS deadlines, which go into effect this year. If you’re focused on preparing your organization to comply, here’s a quick punch list to help you get started:
1. Educate Your Company About the Regulation: Does your team know what GHS is or why it was adopted? If not, take a few moments to clearly explain how this new rule came about and why it’s important. Here’s how I would describe it:
“GHS, or the Globally Harmonized System of Classification and Labeling of Chemicals, was first developed by the United Nations in 2003 to align different hazardous chemical regulations around the world. The standard provides regulatory entities around the world with a universal system to reference when building out their own hazardous chemical regulations. The ultimate goal was to create, among other things, a safer, more sustainable system for international trade.”
As required by the new standard, you should also ensure that your employees have been fully trained on the new label elements and safety data sheet (SDS) format (the deadline for compliance has passed, but this remains an ongoing obligation).
2. Make Sure You Fully Understand the Existing Standard: It’s been nearly three years since OSHA first adopted GHS, but the road to compliance has proven to be a bumpy one. One of the many reasons for this is rooted in long-held misconceptions about what was required to comply with the pre-GHS-aligned HazCom Standard. For this reason, I recommend you take a step back to get level-set on the HazCom basics before diving into the deadlines.
3. Map out the Compliance Deadlines: Once you’ve achieved an accurate baseline understanding of HazCom, you can redirect your attention to the GHS deadlines to identify what is required of them and when in order to ensure compliance. The following is a list of the ones coming up this year and next:
- June 1, 2015: Manufacturers, distributors and importers (as well as employers who take on chemical manufacturing responsibilities) must complete the chemical reclassification process and then re-author their labels and safety data sheets to meet the new GHS-aligned requirements.
- Dec. 1, 2015: Distributors must begin shipping chemicals with the new GHS-aligned SDSs and container labels.
- June 1, 2016: Employers must update their HazCom Programs as needed and complete employee training on any newly identified chemical hazards.
If you’d like more help with putting together a preparation plan, download a copy of our MSDSonline GHS checklist.