GHS - What Employers Need to Do and When
Written by Steve Hudgik
GHS will be phased in between now and June 2016. During this period there are a series of dates that are deadlines which employers must meet. During each section of the transition period chemical manufacturers, importers, distributors, and employers may comply with either 29 CFR 1910.1200 (the final GHS standard), the current standard or both. But following each date they most fully comply with the requirements that went into effect on that date.
Here are the phase-in dates for GHS:
Employers must train workers on the new label elements and Safety Data Sheet (SDS) format by December 1, 2013. OSHA has provided Quick Cards as an aid in training employees in GHS.
Chemical manufacturers, importers, distributors, and employers must fully comply with the new GHS requirements by June 1, 2015. However, until December 15, 2015 distributors may ship products labeled by manufacturers under the old system.
Chemical manufacturers and importers will be required to provide new GHS labels that include a harmonized signal word, pictograms, and a hazard statement based on the hazard classification. Precautionary statements must also be included on the GHS label.
Chemical manufacturers and importers must also provide Safety Data Sheets (SDS) that have a specified 16-section format.
By June 1, 2016, employers must update alternative workplace labeling and hazard communication programs as necessary, and provide additional worker training for new identified physical and health hazards.
Summary of GHS Effective Dates
The table below summarizes the phase-in dates for GHS required under the revised OSHA Hazard Communication Standard (HCS):
Effective Completion Date |
Requirement(s) |
Who Must Do This? |
12/01/2013 |
Employees must be trained on the new label designs and safety data sheet (SDS) format. |
Employers |
06/01/2015* 12/01/2015 |
Full compliance with all of the GHS labeling requirements, except: |
Chemical manufacturers, importers, distributors and employers |
06/01/2016 |
Update any alternative workplace labeling and hazard communication programs as necessary, and provide additional employee training for newly identified physical or health hazards. |
Employers |
During the transition periods above. |
May comply with either the new GHS requirements, the current standard or both |
Chemical manufacturers, importers, distributors, and employers |
