OSHA's adoption of the Globally Harmonized System of Classification and Labelling of Hazardous Chemicals (GHS) reached its first milestone in 2013: the passing of the first compliance deadline. That deadline, December 1, 2013, was the date by which companies covered by the newly revised Hazard Communication Standard, which OSHA now refers to as HazCom 2012, were required to train employees on the new safety data sheet format and on the new required GHS elements on shipped container labels.

Employers with employees covered by the HazCom Standard that did not complete this first round of training are now out of compliance. Such employers, even if acting without malice or intent, are putting employees at risk and undermining the integrity of their businesses. The Hazard Communication Standard has changed and that information must be shared with employees who are vulnerable to hazardous chemicals. Even though the deadline has passed, employers must make it a priority now to get employees caught up on these important changes.

There are additional deadlines on the horizon for all employers, the next of which is June 1, 2015. That is the deadline for chemical manufacturers, distributors and, in some cases, employers to reclassify chemicals using the GHS criteria for health and physical hazards that OSHA adopted, and to update safety data sheets and labels with the changes discussed above. Even though the next deadline is over a year away, employers need to understand that the ramifications of the 2015 deadline are already being felt, and that employers must be active in the troughs between deadlines to ensure they do not fall out of compliance.

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