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Deadlines to Comply With The NEW Hazard Communication Standard Are Fast Approaching

By Robinson+Cole's Manufacturing Industry Group on March 22, 2013
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As I type this, it’s the first day March Madness, the first day of spring (despite the snow on the ground outside), and December 1, 2013 seems very far away.   Yet, it’s the first deadline in the new, revised Hazard Communication standard. 

A quick review: On March 21, 2012, OSHA revised the Hazard Communication Standard (HCS) to align it with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS).  The GHS is an international approach to hazard communication, providing agreed upon criteria for the classification of chemical hazards, and a standardized approach to label elements and safety data sheets. 

OSHA’s goals in revising the HCS were to improve both the quality and consistency of information about chemicals in the workplace, provide employees with easier to understand labels and information on handing hazardous chemicals, and to reduce trade barriers by ensuring that the new Safety Data Sheets and labeling are consistent with those used around the world. 

Major changes in the new HCS include:

  • The classification of hazardous chemicals
  • Standardizing the format of the safety data sheet
  • The use of pictograms rather than the hazard diamond in labeling

OSHA has put together a side-by-side summary of the differences between the 1994 and 2012 HCS to help employers understand their responsibilities.

OSHA has set several compliance deadlines.  The first is December 1, 2013.  All employees must be trained on the new label elements, such as pictograms, and the new Safety Data Sheet format. 

While December 1 seems like it’s a long way away, deadlines have a way of creeping up on us.  It may be prudent to use upcoming refresher training to fulfill these requirements.  And for those new employees you’re hiring, consider revising your training now and training them on HCS 2012, so you don’t have to retrain them again before December 1.

  • Posted in:
    Environmental and Climate
  • Blog:
    Manufacturing Law Blog
  • Organization:
    Robinson & Cole LLP
  • Article: View Original Source

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