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March 28, 2012

OSHA has announced significant changes to its Hazard Communication Standards, the rules that govern MSDS sheets, chemical warning labels, and employee training in the risks posed by hazardous chemicals.  These new rules will affect every employer who is required to have a hazard communication program, train employees in the use of MSDS sheets, and prepare its own MSDS sheets for products. The changes conform the OSHA hazard communication regulations to the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals, or “GHS”, and will affect chemical safety training, labeling and safety data sheets for all chemicals manufactured in the United States and imported from abroad.   OSHA’s goal is to improve hazard communication, especially for low literacy workers, and to establish consistent, uniform standards for safety data sheets and other forms of hazard communication.

The new hazard communication rules will be fully implemented by June 1, 2016, but there are several interim deadlines.  Employee training on the new label and safety data sheet requirements must be completed by December 1, 2013.  Chemical manufacturers, importers and distributors must comply with all modified labeling and safety data sheet requirements by June 1, 2015.  By December 1, 2015, chemical distributors will be prohibited from shipping a chemical container labeled by the manufacturer or importer unless it has a label that conforms to the new standards.  All employers must have updated their hazard communication and safety programs to meet the new requirements.

During the transition to the new hazard communications standards, employers may comply with either the current standards or the new standards.  However, the deadlines are not that far away, and all employers should develop a plan for compliance with the new hazard communication rules.
 

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