May 16, 2015
Is your hazard communication program up to date? It should be. On June 1, you need to be in compliance with all the elements of the GHS-aligned hazard communication program.
If you have identified any new hazardous chemicals since Dec. 1, 2015 (the date that manufacturers, importers, and distributors had to use GHS-compliant labels), make sure that you have documented those hazards in your hazard communication program and that you have properly labeled the chemical containers. If you use "alternative" labeling methods for individual stationary process containers, update those labels, too.
Also, replace old Material Safety Data Sheet-formatted documents with GHS-aligned Safety Data Sheet-formatted documents.
Finally, be sure you have trained your employees about the effects of those new chemical hazards.
And just in case you are wondering what has been going on with the hazard communication standard over the past three years, here is a summary of the phase-in dates for the GHS-aligned standard:
Deadline: Dec. 1, 2013
Requirement: rain employees on the new label elements and safety data sheets (SDS) format.
Deadline: June 1, 2015
Who: Chemical manufacturers, importers, distributors, and employers
Requirement: Compliance with all modivied provisions of this final rule, except distributors have an additional six months to ship products without GHS labels.
Deadline: Dec. 1, 2015
Requirement: Must not ship containers without a GHS label.
Deadline: June 1, 2016
Requirement: Update alternative workplace labeling and hazard communication program as necessarry, and provide additional employee training for newly identified physical or health hazards.
In this issue:
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