May 22, 2012

GHS is a Globally Harmonized System of classification and labeling of chemicals, and it's about to affect your workplace. Even though you've probably had an effective and compliant hazard communication program in place for a while now, it's about to become obsolete. This is because OSHA has just released the long-awaited Final Rule that aligns its Hazard Communication Standard with the United Nations Globally Harmonized System (GHS).

The changes to the current rules are sweeping. How should you proceed from here, now that we finally have the official word from OSHA? In a BLR webinar titled "The Hazard Communication Standard: Significant Changes are Finally Here – Are You Ready for GHS?," Brad Harbaugh outlined some basics to help you get started.

OSHA Hazard Communication Standard: When Will the Revised Version Go Into Effect?

OSHA alignment with GHS will soon go into effect, but there will be a transition period for compliance. Harbaugh explained that "OSHA adopted GHS, or revised the hazard communication standard (HAZCOM 2012) on March 26 of this year" and it goes into effect May 25, 2012. The first of the compliance dates " the first dates that you really have to be looking at and thinking about … is December 1st, 2013," Harbaugh explained. "This is the date by which employers must train their employees on how to read safety data sheets and labels in the GHS format."

Training is first because we already have customers seeing the new GHS-formatted safety data sheets and labels. The primary changes for most employers are new chemical classifications, new safety data sheets (SDSs), and new labels. OSHA anticipated that there will be more early adopters of these changes, and workplaces could start seeing more GHS-compliant labels and SDSs well before the 3 year mark. OSHA wants to ensure employee safety during the transition. OSHA also understands that during the transition, some employers will be following the old Hazard Communication Standard (HCS) and some the revised HCS; to that end, the agency will enforce compliance, but will accept adherence to either standard so long as the company in question is compliant with the old or the new HCS.

Additional compliance dates to be aware of include:

• June 1, 2015. Chemical manufacturers and distributors must complete their reclassification of chemicals based on the GHS criteria and update their safety data sheets (SDSs) and labels by this date.
• December 1, 2015. Distributors may ship inventory with old SDSs and labels until this date. Harbaugh confirmed that "distributors get an extra 6 months to get rid of their old inventory," hence the different date of compliance for them.
• June 1, 2016. Full employer compliance is expected by this date. Harbaugh explained that "this is the date by which employers must train their employees on any of the new hazards that have been identified during that reclassification process, to make sure that employees understand how to read the specific safety data sheets for the chemicals that they're using in their facility, to understand any updates to the hazard communication program, to understand any changes to the workplace labeling system and such."

During the transition period, you should be incompliance with either the old or the new HCS, or some combination, but never out of compliance with both.

GHS and HCS Principles of Alignment

The most important thing to remember is that the overall protections that are outlined in the HCS will not be reduced; rather, OSHA is making the standard more comprehensive. That said, OSHA is only modifying those provisions of the HCS that must be changed to align with the GHS, but the basic framework will remain the same. In other words, it's not a total re-write of the regulation. Chemical manufacturers and importers will continue to be responsible for providing information about the identities and hazards of the chemicals they produce or import. All employers with chemicals in their workplaces will continue to be responsible to have a hazard communication program and provide information to their employees about their hazards and protective measures.

With the primary changes coming to hazard classifications, SDSs, and labels, your best move is to start preparing your training now.

For more information on GHS and the upcoming changes to the hazard communication standard, order the webinar recording. To register for a future webinar, visit http://catalog.blr.com/audio.

Brad Harbaugh is editor of the Environmental Health and Safety blog for MSDSonline – a leading provider of on-demand compliance solutions for managing chemicals, material safety data sheets (MSDSs), OSHA Recordkeeping, and other critical EH&S tasks. In addition to researching and reporting on current EH&S issues, Brad is the creator of MSDSonline's popular GHS Answer Center and GHS Webinar series.