READY OR NOT: EMPLOYERS NEED TO BE PREPARED FOR FINAL HAZARD COMMUNICATION STANDARD DEADLINE

Although passed more than two years ago, the final deadline for implementing the revised OSHA Hazard Communication Standard (HCS) and new Globally Harmonized System (GHS) is coming up on June 1, 2016.  By that date, employers will need to ensure that their hazard communication program has been fully updated along with providing training to all employees on the new standards. 

In addition, employers must update chemical labeling throughout the workplace with the new pictograms and replace the old Material Safety Data Sheets with the new Safety Data Sheet (SDS), which contains the revised format with strict ordering of 16 specific sections.  It is important to ensure that employees are trained on the SDS format and hazard warning information with the new labeling and pictograms.  Employers will need to review their current chemical inventory and contact suppliers to obtain the newly formatted SDSs.

Unfortunately, some chemical manufacturers and distributors have missed prior deadlines to reclassify hazardous chemicals and have failed to draft SDSs that comply with the new format.  This has left employers in a tough position since ultimately it is their responsibility to obtain the updated SDSs and make the information available to employees.  OSHA expects employers to play an active role in getting suppliers to comply with the new standards so it will be important to document the good faith efforts made to obtain the new SDSs prior to the deadline.

Employers have now had more than two years to update their HAZCOM programs, incorporate the new SDSs and provide updated training to its employees.  So ready or not, OSHA will not be shy to cite companies that have failed to comply with the new standards by this final deadline coming up in a few weeks.