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June 2016 GHS Timetable

By Graphic Products Editorial Staff (https://plus.google.com/+Graphicproductsinc/about)
Published: Aug 1, 2014
Updated: Jan 26, 2016

With its publication in the Federal Register on March 26, 2012, the new OSHA Hazard
Communication Standard (HCS) established its alignment with the Globally Harmonized
System (GHS) of Classification and Labeling of Chemicals in the United States. This resulted
in changes in:
Chemical hazard classification
Labeling of chemicals
Safety Data Sheets (SDS) which are replacing Material Safety Data Sheets (MSDS)
Training of employees

WhatistheJune2016GHSTimetable?
Because the GHS alignment, significant changes were introduced. OSHA established a
transition timetable that provided time for training employees, for acquiring new label
printing capabilities, and for using up existing stocks of chemicals which already had been
labeled under the old system. The timetable stretches until June 2016 for a 100%
transition to GHS. Its critical to know the milestone dates along the way in order to stay
compliant.
December 1, 2013 All employees who use, handle, or store chemicals needed to
have been trained on the new label elements and safety data sheet (SDS) format.
June 1, 2015 All chemical manufacturers, importers, and distributors must be in

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compliance with the 2012 OSHA HCS requirements. This includes classification of
chemicals, preparation of safety data sheets, and preparing GHS labels.
December 1, 2015 The grace period ends for shipping existing inventory that had
older labels. All shipments of chemicals must have the new GHS compliant labels.
June 1, 2016 All employers must be in full compliance with the new HCS. This
includes having updated their written workplace hazard communication program to
incorporate the new GHS requirements. The training of employees on their new
workplace hazard communication program must also be completed.

June2016GHSTimetableWhatNeedstobeDone?
OSHA lists six steps for being in full compliance with the 2012 HCS.

1.IdentifyResponsibleStaff
Responsibility for implementation of hazard communication should be assigned to a
specific person. That person then identifies and coordinates those who are responsible for
completing specific activities, and is responsible for ensuring they are familiar with the
OSHA HCS.

2.PrepareandImplementaWrittenHazardCommunication
Program
This is a written plan describing how hazard communication will be accomplished in your
workplace. All workplaces must have a written hazard communication plan, except for
laboratories and work operations where employees only handle chemicals in sealed
containers.
The hazard communication plan does not have to be complicated, or lengthy. It is simply a
description of how hazard communication will be accomplished in your facility such that all
employees are fully aware of the chemical hazards in their workplace. If you are a
member of trade associations, or other type of industry group, you may find they already
have sample programs available that are tailored specifically to your industry. If you base
your program on a generic example, be sure it has been modified to accurately reflect the
chemicals you use in your workplace, the physical arrangement of your facility, and the
type of work you do.
One of the key requirements for your plan is that it must include a list of the hazardous
chemicals known to be present in your workplace. This list makes it easier to ensure you
have all of the necessary safety data sheets and completed the required labeling.
Your hazard communication program should also cover the procedures for informing
employees about hazards associated with non-routine tasks. For example, vessels or
tanks may be cleaned infrequently, so workers may not be familiar with the cleaning

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procedures. Those doing the cleaning will need to be trained so they know about the
hazards associated with the materials the vessels and tanks held, and how they can
protect themselves from those hazards.

3.EnsureContainersAreLabeled
Chemicals will arrive at your facility in containers that have GHS labels
(https://store.graphicproducts.com/en-us/duralabel/standards-compliance/hazmatcompliance/ghs). Those labels should be kept in place. If they are damaged, they will need
to be replaced. Most workplace containers the containers that never leave your
workplace must be labeled. A container holding a hazardous material must, at a
minimum, have a label with the product identifier and general information about the
hazards associated with that material. In all cases your employees must be fully informed
about chemical hazards, although some information may be supplied through means
other than labels.
OSHA states that your hazard communication program should provide the following
information about container labeling:
For workplace chemical containers:
Identify the person responsible for ensuring all workplace containers are
labeled;
Provide a description of the system to be used for labeling workplace
containers;
When applicable, describe alternatives to labeling of workplace containers;
For chemical containers shipped from your facility:
Identify the person who is responsible for ensuring the containers are
properly labeled;
Describe the labeling system used for making GHS labels for shipments from
your facility;
Establish procedures for reviewing and updating labeling information.

4.MaintainSafetyDataSheets(SDSs)
You must have readily available safety data sheets (/guides/safety-data-sheet-sds/) for
every hazardous chemical in your workplace. They are the source for detailed information
about the hazards of a chemical.
Have SDSs readily available. Having copies in binders placed around the workplace is one
example. Keep in mind that employees who work in the field also need ready access to
SDSs. This may mean keeping SDSs in the cabs of pickup trucks, or in mobile offices.

5.InformandTrainEmployees
It is the employer's responsibility to train all employees. OSHA states:

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Paragraph (h) of the HCS requires that

employers train employees on the hazardous
chemicals in their work area before their initial
assignment and when new hazards are introduced
into the work area, and this training must be
conducted in a manner and language that employees
can understand. Workers must understand they are
exposed to hazardous chemicals. They must know
that labels and safety data sheets can provide them
with information on the hazards of a chemical, and
these items should be consulted when needed. In
addition, workers must have a general understanding
of what information is provided on labels and SDSs,
and how to access them. They must also be aware of
the protective measures available in their workplace,
how to use or implement these measures, and whom
they should contact if an issue arises.

6.EvaluateYourProgram
Your written hazard communication program should be reviewed periodically, and revised
if changes are necessary due to changes in the workplace, the use of new chemicals,
changes in work procedures, or any other changes that might result in exposure to

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chemical hazards. Your hazard communication program must remain current and
applicable to the existing conditions in your facility.

June2016GHSTimetableFreeBestPracticesGuide
For more information about GHS labeling for both domestic and international shipments,
request a free copy of the International GHS Labeling Best Practices Guide
(/guides/international-ghs-labeling/). This best practice guide provides a concise overview
of the information needed to be GHS compliant.

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