Deadline for GHS and SDS Compliance – June 1st, 2016

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As part of the revised Hazardous Communication Standard, OSHA adopted the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS) in 2012.  Compliance with GHS has been in multiple stages over the last several years, but the final deadline for all end-users is June 1st, 2016.   This system includes the new standard 16-section Safety Data Sheet (SDS) format.

The initial GHS training for all employees should have been completed by December 1st, 2013 but should continue annually thereafter.  Training should include reviewing the label requirements, how the label elements work together, the use of labels in the work place, the new 16-section SDS format and how to access the SDS when necessary (29 CFR 1910.1200(b)(3)(ii).  Most importantly, the training must be understandable to the employees, taking into account any limitations in employee vocabulary or literacy, and if applicable the training should be offered in languages other than English.  Timely communication to the employees of any revisions or updates to the SDS and labels is also required to ensure employee safety.

Where do the SDS and labels originate?

Manufacturers, distributors or importers of hazardous chemicals are required to provide the SDS to the end-users. If any significant changes are made to the information on the labels or SDS, the manufacturer or distributor must provide new labels and Safety Data Sheets within 6 months of the revision (29 CFR 1910.1200(f)(11). End-users must be sure that all labels on the hazardous chemicals remain intact and readable

(29 CFR 1910.1200(b)(4)(i).

Are any chemicals in the workplace excluded from SDS and labeling requirements?

Many chemicals overseen by other government agencies such as pesticides (EPA) and food additives (FDA) have other regulatory issues and do not require an Safety Data Sheet.  Another exclusion is any household consumer product (CPSC) that is used in the workplace in the same manner that a consumer would use it.  This exemption in OSHA’s regulation is based on the actual use of the chemical in the workplace (29 CFR 1910.1200(b)(ix). If employees are required to work with hazardous chemicals with a duration and frequency of exposure greater than what normal consumers would experience, the employees would have a right to know about the properties of those hazardous chemicals.  A general exception to the SDS requirement is any non–hazardous chemicals used in the workplace; OSHA does not recommend SDS on any non-hazardous chemical as it may be confusing to those at risk of possible exposure.
Full text of the OSHA Revised Hazardous Communication Standard for Toxic and Hazardous Substances


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