By James L. Curtis and Ilana R. Morady
As we noted in a blog earlier this year, on December 1, 2013, employers must begin complying with OSHA’s new Hazard Communication (HazCom) standard.
The Agency had revised its HazCom standard (77 Fed. Reg. 17574 (March 26, 2012)) to align with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS), which is an international standardized approach to elements of hazard communication. With OSHA’s adoption of the GHS come mandated changes that are listed out in our earlier blogs, including: Safety Data Sheets (SDSs); hazard classification; and labeling requirements.
December 1, 2013 is the deadline by which employers must have trained employees on the new label elements and SDS format. As OSHA inspectors are going to be looking for these elements on their site visits, employers need to make sure that all of their policy manuals and training programs are compliant with these new rules.