As the EIA reported in March, the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS) has been adopted by Fed/OSHA. On May 6th, Cal/OSHA also adopted the standards in areas where the codes do not conflict. This means that some changes between the two codes may occur over time, with the Cal/OSHA code possibly becoming more comprehensive. Please see the administrative documentation of the adoption.
When Will the Revised Version Go Into Effect?
The first of the compliance dates is December 1, 2013. This is the date by which employers must train their employees on how to read safety data sheets and labels in the new GHS format.
Additional compliance dates to be aware of:
June 1, 2015 - Chemical manufacturers and distributors must complete their reclassification of chemicals based on the GHS criteria and update their safety data sheets (SDSs) and labels by this date.
December 1, 2015 - Distributors may ship inventory with old SDSs 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:
- • Provide additional training regarding any of the new hazards that have been identified during that reclassification process
- • Update all labeling and Hazard Communication programs to align them with the new Cal/OSHA 5194 standard.
Below is the Federal OSHA Matrix showing the GHS or HAZCOM 2012 Implementation dates:
Start Preparing Early
With the primary changes coming to hazard classifications, SDSs, and labels, it is highly suggested that preparation begin now.
It is also recommended that employers check the Cal/OSHA web site for any implementation guidance to ensure proper awareness of any resolution to areas of conflict between Cal/OSHA and Federal OSHA in regards to Hazard Communication.
Helpful Employer Tools
The Federal OSHA staff has been preparing for this change for some time and has developed several employer tools that can and should be used to implement these new requirements. The first three provide general information on Global Harmonization from the Federal OSHA staff. While it is good information, remember: we are regulated by Cal/OSHA, not the Federal OSHA program.
Federal OSHA GHS Rule Guidance
Federal OSHA GHS Fact Sheet on Training
Federal OSHA GHS Fact Sheet on Labels and Pictograms
These Quick cards should be very useful in implementing the December 1st training requirements and are being recommended for use by Cal/OSHA. These are seen as the basis for safety committee meetings and tail gate meetings to accomplish this training task.
GHS Pictogram Quick Card to be used in training
GHS Labeling Quick Card to be used in training
SDS Quick Card used in training on SDS Content
The training that is required by December 1st, 2013 (train employees on the new label elements and SDS format) is pretty straight forward and should be fairly easy for any entity to implement.
We hope you find this information useful and if we can be of further assistance, please feel free to contact the EIA Loss Prevention department at 916-850-7300.
