Blog Post Chart Your GHS Compliance During the Transition Period


Mar

19

2013

Chart Your GHS Compliance During the Transition Period

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By Chris Kilbourne

HazCom Plan Update

By June 1, 2016, you must update your written hazard communication plan as necessary to reflect the new chemical label design and SDS format. The revised plan must also describe any changes to employee training requirements related to hazard classification and make chemical labels and SDSs understandable.

Your revised plan should include the following components:

  • Identification of participating personnel
  • Description of the methods you will use to inform employees of the hazards of non-routine tasks (such as cleaning reactor vessels) and hazards associated with chemicals contained in unlabeled pipes in work areas
  • Criteria for labels and other forms of warning, including:
    • Designation of person responsible for ensuring labeling of in-plant containers;
    • Designation of person responsible for ensuring labeling of shipped containers;
    • Description of labeling system used;
    • Description of written alternatives to labeling of in-plant containers, where applicable: and
    • Procedures to review and update label information, when necessary
  • Criteria for SDSs, including:
    • Designation of persons responsible for obtaining/ maintaining the SDSs;
    • How the SDSs are to be maintained (e.g., in notebooks in the work area(s), in a pickup truck at the jobsite, via fax), procedures on how to retrieve SDSs electronically, including backup systems to be used in the event of failure of the electronic equipment, and how employees obtain access to the SDSs;
    • Procedures to follow when the SDS is not received at the time of the first shipment; and
    • For chemical manufacturers or importers, procedures for updating the SDS when new and significant health information is found
  • Criteria for employee training, including:
    • Designation of persons responsible for conducting training;
    • Format of the program to be used (audiovisuals, classroom instruction, etc.);
    • Elements of the training program, if the written program addresses how the duties outlined in the regulation for employee information and training will be met;
    • Procedures to train new employees at the time of their initial assignment and to train employees when a new hazard is introduced into the workplace; and
    • Procedures to train employees regarding new hazards to which they may be exposed when working on or near another employer’s worksite (e.g., hazards introduced by other employers.)

Download the GHS Implementation Timeline Here

May 25, 2012 to November 30, 2013
All employers that use, handle, store chemicals

Train employees how to read and interpret chemical labels and (material) safety data sheets in compliance with either:

  1. The pre-GHS HazCom standard for labels and MSDSs; or
  2. The revised HazCom standard with GHS for new-style labels and SDSs; or
  3. Both old and new requirements at the same time

December 1, 2013
All employers that use, handle, store chemicals

Train employees about the new GHS-compliant chemical labels and SDSs.

June 1, 2015
Chemical manufacturers, importers, distributors

Comply with all the requirements of the GHS rule, including classify chemical hazards and prepare new labels and SDSs. Distributors have until December 1, 2015 to comply with the shipping requirements for GHS-compliant labels.

December 1, 2015
All employers that use, handle, store chemicals

All shipments of chemical containers must include the new GHS-compliant label (signal word, pictogram, hazard statement, and precautionary statement).

June 1, 2016
All employers that use, handle, store chemicals

Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards.

 

 

 

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