June 1, 2015 is the deadline by which manufacturers, distributors, and importers must reclassify chemicals and update all SDSs and labels to the new GHS format. Many in the industry are in the process of preparing, but some still have questions about what will change for them, and what they’ll need to do in order to be fully compliant.
Under GHS, chemical hazard classification and communication have changed.
Regarding classification, with GHS, manufacturers, importers, and distributors are called upon to reclassify chemicals, which involves the following steps: 1.) gather and review relevant data associated with the chemical, 2.) identify the health and physical hazards associated with the chemical (if there are any), and 3.) determine the degree of the hazard. This final step is a new responsibility for classifiers of chemicals; no longer are they simply making a determination as to whether a chemical is hazardous or not, they must also communicate the severity of the hazard.
Regarding hazard communication, these same upstream suppliers are required to update their safety data sheets and labels in the GHS format…all by June 1.
On May 14, VelocityEHS will be hosting a free, live Webinar covering the steps employers and chemical manufacturers should take to prepare for the June 1 deadline. For more information on VelocityEHS webinars, or to register, click here.
GHS Adoption Timeline
Stepping back, it’s important to remember that this June 1 deadline is just the next in a series of ongoing deadlines we’re facing as OSHA transitions toward GHS implementation.
- December 1, 2013 — This was the date by which employers need to train employees on how to read SDSs and labels in the GHS format. OSHA has this as the first deadline because it believes employers will be seeing GHS formatted labels and safety data sheets in their facilities sooner rather than later, and it’s important that employees be comfortable with the new formats, even if their companies are not yet fully compliant.
- June 1, 2015 — The deadline we face now, this is the date by which manufacturers and importers must reclassify their chemicals and produce/update GHS formatted labels and safety data sheets.
- December 1, 2015 — Distributors actually get a little special dispensation—they have until this date to get rid of old inventory with old labels. Effectively, they can continue using the pre-GHS labeling system until December 1.
- June 1, 2016 — The final deadline, this is the date by which employers must be in full compliance with GHS. That means making any necessary updates to their hazard communication programs, training employees on new hazards identified in during the reclassification process, updating workplace labels, and anything else required by HazCom 2012.
OSHA understands that during the transition to GHS, things could get a little messy. That’s why, during the transition period, a company can be in compliance with old HCS, the new GHS system, or a combination of both. However, more importantly, at no time may an employer be out of compliance with both the old and the new.
We realize that all of this might seem challenging. That’s why VelocityEHS’ offerings help companies comply with GHS HazCom requirements in several ways:
- We offer access to the industry’s largest library of updated SDSs, including SDSs in the GHS format.
- We search the marketplace for the most recent SDSs, and upload approximately 20,000 new or revised safety data sheets into our system each week. We also give users the ability to upload their own SDSs or request that we retrieve a needed SDS.
- We flag safety data sheets in our system that are in the GHS format and make it easy to search, track and manage your SDSs across your organization
- We offer expert safety data sheet authoring in the GHS format services to chemical manufacturers and distributors.
- We provide on-demand training on GHS, HazCom and a variety of related topics.
Wherever you are in your company’s transition toward GHS, the time to get started is now! A great place to brush up on your GHS knowledge is at our online GHS Answer Center.