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November 5, 2013

Countdown to December 1: How to Meet OSHA’s Training Deadline

Bergeson & Campbell, P.C.

There are 26 days remaining until the December 1 deadline by which employers must have trained their workers on the new label elements and the Safety Data Sheet (SDS) format as required under the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). While there is still time to meet the requirements, companies must act quickly.

Bergeson & Campbell, P.C. (B&C®) and The Acta Group (Acta) can assist employers storing, using, or handling chemicals to meet this deadline by providing:

  • On-site training for employees on new label elements and the SDS format;
  • A webinar to train employees on new label elements and the SDS format; and
  • Compliance audits to verify completion of training by the deadline.

See the Occupational Safety and Health Administration (OSHA) Fact Sheet, for full compliance details.

December 1, 2013, is just the first of four deadlines that OSHA has scheduled over the next three years to complete the alignment of the U.S. Hazard Communication Standard (HCS) with GHS. The complete document describing the GHS, why it was developed, and how it relates to the sound management of chemicals can be found on OSHA’s website.

Major Changes to the HCS:

  • Hazard Classification: Chemical manufacturers and importers are required to determine the hazards of the chemicals they produce or import. Hazard classification under the new standard provides specific criteria to address health and physical hazards as well as classification of chemical mixtures.
  • Labels: Chemical manufacturers and importers must provide a label that includes a signal word, pictogram, hazard statement, and precautionary statement for each hazard class and category.
  • SDSs: The new format requires 16 specific sections, ensuring consistency in presentation of important protection information.
  • Information and Training: To facilitate understanding of the new system, the new standard requires that workers be trained by December 1, 2013, on the new label elements and SDS format, in addition to the current training requirements.

What You Need to Do and When:

  • Chemical Users: Continue to update SDSs when new ones become available, provide training on the new label elements, and update hazard communication programs if new hazards are identified.
  • Chemical Producers: Review hazard information for all chemicals produced or imported, classify chemicals according to the new classification criteria, and update labels and SDSs.
Effective Completion DateRequirement(s)Who
December 1, 2013Train 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, 2016Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards.Employers
Transition PeriodComply with either 29 C.F.R. Section 1910.1200 (this final standard), or the current standard, or both.All chemical manufacturers, importers, distributors, and employers