Implementing New Global Harmonization Standard Changes

The United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS) has been adopted by Fed/OSHA.

Cal/OSHA has not yet changed its standard, but it is an item on the 2013 Standards Board Agenda. There is speculation that Cal/OSHA will first adopt the federal standard, essentially “as is” due to a lack of budget and then make changes to conform to specific state needs such as what to do with Prop 65 Chemicals and differing chemical classification systems.

When Will the Revised Version Go Into Effect?

December 1st, 2013, is the date by which employers must train their employees on how to read safety data sheets and labels in the GHS format.

Training is first because employers are already seeing the new GHS-formatted safety data sheets (SDS) and labels associated with the products they are buying. The primary changes for most employers include:

• New chemical classifications
• New safety data sheet (SDS) format
• New labels

Additional compliance dates to be aware of include:

June 1, 2015 - Chemical manufacturers and distributors must complete their reclassification of chemicals based on the GHS criteria and update their safety data sheets (SDS) and labels by this date.

December 1, 2015 - Distributors may ship inventory with old SDS and labels until this date. In effect, distributors get an extra 6 months to “use up” their old inventory, hence the different date of compliance for them.

June 1, 2016 - Full employer compliance is expected by this date. This is the date by which employers must train their employees on:

• Any of the new hazards that have been identified during that reclassification process
• How to read the specific safety data sheets for the chemicals that they are using in their facility
• How to understand any updates to the hazard communication program
• How to understand any changes to the workplace labeling system

Below is the Federal OSHA Matrix showing the GHS or HAZCOM 2012 Implementation dates:

During the transition period, employers should strive to be in compliance with either the old or the new Hazard Communication 2012 Standard, including the new GHS requirements. Employers will want to avoid being out of compliance with both.

With the primary changes coming to hazard classifications, SDSs, and labels, your best move is to start preparing today.

You should continue to check the Cal/OSHA website for any guidance on implementation so you will be aware of any proposed or adopted California specific regulation.

For more information on GHS and the upcoming changes to the hazard communication standard, see Federal OSHA.