The final deadline in OSHA’s four-step conversion to the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) is less than three months away. By June 1, 2016, employers, manufacturers, importers and distributors of hazardous chemicals will have to be in full compliance with the revised hazard communication standard (HCS). OSHA adopted GHS in 2012 to make labels and Safety Data Sheets (SDSs) consistent with those used in most of the rest of the world.

Previous compliance deadlines were December 1, 2013, by when employers needed to have trained employees about the format and presentation of the new GHS labels and safety data sheets (SDSs) they will be seeing in the workplace; June 1, 2015, by which date all new labels and SDSs from manufacturers, importers and distributors needed to completed; and December 1, 2015, the date when manufacturers, importers and distributors could no longer use 1994 HCS-compliant labels.

According to the OSHA document Small Entity Compliance Guide for Employers That Use Hazardous Chemicals:
“If an employer identifies new hazards after December 1, 2015, due to the reclassification of the hazardous chemicals, it has six months, until June 1, 2016, to ensure that those hazards are included in the hazard communication program, workplace labeling reflects those new hazards, and employees are trained on the new hazards.”

According to that same document, OSHA inspections will be looking for at least the following aspects of an organization’s labeling approach:

-Designation of person(s) responsible for ensuring compliant labeling of shipped and inplant containers;
-Description of written alternatives to labeling of stationary process containers, if they are used;
-Appropriate labels on all workplace containers, including those received from a supplier, secondary containers, and stationary process containers;
-A description and explanation of labels on both shipped and workplace containers included in the employee training program; and,
-Procedures to review and update workplace label information when necessary.

Here is some more food for thought, even if your organization doesn’t handle chemicals: According to Federal OSHA, the HCS has been the second most violated standard it cites – 5482 times in 3055 federal OSHA inspections from October 2014 to September 2015, with a total of $3,308,262 in proposed penalties. The fall protection standard for construction took the top spot.