REGULATORY ALERT: FINAL DEADLINE FOR IMPLEMENTATION OF HAZ COM 2012 IS APPROACHING

19 April, 2016

What’s Happening?

June 1, 2016 is the final compliance date associated with the implementation of OSHA’s Hazard Communication Standard 2012 (29 CFR 1910.1200) which provides for the adoption of GHS (Globally Harmonized System of Classification and Labelling of Chemicals).

How Could it Impact Me?

By June 1, 2016, all employers must be in full compliance with the revised Hazard Communication Standard.  This includes training of employees on newly identified physical and health hazards, revisions (as necessary) to the employer’s written hazard communication program and updating of any alternative workplace labeling, if needed.

Quick Summary:

Training
Additional employee training must be completed addressing any newly identified physical and/or health hazards associated with chemicals in the workplace.

Written Hazard Communication Program

Employers must revise (if necessary) the written Hazard Communication Program to reflect the requirements of the newly implemented Hazard Communication Standard.

Workplace Labeling

If an employer has an in-plant or workplace labeling system that is compliant with HazCom 1994, the employer may continue to use this system as long as this system, in conjunction with other information that is immediately available to employees, provides employees with the information on all health and physical hazards associated with a hazardous chemical.

Employers may use alternative labeling (signs, placards, process sheets, batch tickets, operating procedures or other written material in lieu of affixing labels to individual stationary process containers.  This method is permitted as long as the alternative method identifies the containers and conveys the information required by the standard (product identifier and words, pictures, and/or symbols that communicate the hazards of the product).

If an employer chooses to use the GHS pictograms that appear in Appendix C of the Hazard Communication Standard, the pictograms may have a black border, rather than a red border. 

Elizabeth Dederick, Ph.D. Vice President, Industrial Chemicals and Biocides
+1 610 558 3001 Ext. 102 +1 610 558 6025 send mail