Tuesday, December 11, 2012

New Hazard Communication Standard Q & A Part 2

Q. What is the phase-in period in the revised Hazard Communication Standard?

A. The table below summarizes the phase-in dates required under the revised Hazard Communication Standard (HCS):
Effective Completion Date
December 1, 2013
Train employees on the new label elements and safety data sheet (SDS) format.
June 1, 2015*
December 1, 2015
Compliance with all modified provisions of this final rule, except:
The Distributor shall not ship containers labeled by the chemical manufacturer or importer unless it is a GHS label
Chemical manufacturers, importers, distributors and employers
June 1, 2016
Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards.
Transition Period to the effective completion dates noted above
May comply with either 29 CFR 1910.1200 (the final standard), or the current standard, or both
Chemical manufacturers, importers, distributors, and employers
*This date coincides with the EU implementation date for classification of mixtures
During the phase-in period, employers would be required to be in compliance with either the existing HCS or the revised HCS, or both. OSHA recognizes that hazard communication programs will go through a period of time where labels and SDSs under both standards will be present in the workplace. This will be considered acceptable, and employers are not required to maintain two sets of labels and SDSs for compliance purposes.

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