When federal OSHA adopted the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) in 2012, a compliance clock started ticking. And when Cal/OSHA began adopting the federal rule, it retained federal OSHA's deadlines, meaning California employers don't have extra time to comply with the changes.

Ultimately, the goal of GHS is to reduce the compliance burden for manufacturers, importers, distributors, and end users of chemicals by creating a single international standard for chemical hazard classification, labeling, and safety data sheets (SDSs).

During the implementation period—and while some agencies both in the United States and abroad are still aligning their rules with GHS--chemical manufacturers and users have a lot of work to do.

To make the transition manageable, federal OSHA created a staggered series of compliance deadlines for the changes. The next deadline, December 1, 2015, is fast approaching. How's your compliance?

Practice Tip

You may need to provide ongoing retraining to workers as chemical hazard classifications and information are updated.

First deadline: December 1, 2013

By December 1, 2013, employers were supposed to have trained workers in the updated label format and terminology and SDSs that will replace the existing requirements for material safety data sheets (MSDSs).

GHS-compliant labels include signal words, pictograms, hazard statements, and precautionary statements. Workers must be trained in and understand the meaning of each of these elements. GHS-compliant SDSs must follow a standardized 16-section format that includes specific information about a hazardous chemical's health effects and physical and chemical characteristics. The updated SDSs must be prepared by suppliers and shipped to end users.

Have you updated your training yet?

Second deadline: June 1, 2015

By June 1, 2015, chemical manufacturers, distributors, and importers, as well as employers, should have finished updating the classification of hazardous chemicals and updated all SDSs and labels to the new GHS format. One exception to the requirement was allowed—for distributors. Until December 1, distributors were permitted to ship containers with non-GHS labels if they had received the containers from suppliers before June 1, 2015.

Have your hazard classification and labels been updated yet?

Third deadline: December 1, 2015

As of December 1, 2015, all containers should be shipped with GHS-compliant labels. If you're a distributor and you still have stock with non-GHS labels, those labels must be updated. If you are an end user, and you receive a container with a noncompliant label after December 1, you should request a compliant label from the distributor.

Are your labels for in-stock items up to date?

Fourth deadline: June 1, 2016

The final federal OSHA and Cal/OSHA compliance deadline is June 1, 2016. By that date, all affected employers must:

• Update any alternative labeling used in the workplace;


• Update their written hazard communication programs; and


• Provide any additional employee training needed for chemicals with newly identified physical or health hazards.

What's the status of your alternative labels and written program elements?

GHS outside the HCS

Just as OSHA was not the only agency whose chemical hazard classifications and labeling were affected by GHS (the U.S. Environmental Protection Agency, U.S. Department of Transportation, Consumer Product Safety Commission, and related state agencies are also in various stages of aligning with GHS), the hazard communication standard (HCS) was not the only standard that the GHS changes impacted.

Thirty different sections of the Construction Safety Orders, General Industry Safety Orders, and the Ship Building, Ship Repairing, and Ship Breaking Safety Orders and their appendices are also affected. Essentially, any standard dealing with the identification, classification, and labeling of hazardous chemicals has been or will be altered to comply with the new definitions and labels the GHS requires.

The state Occupational Safety and Health Standards Board (OSHSB) is still in the process of revising each of these standards to comply with GHS.