The Dodge Company is working towards compliance with the new Hazard Communication Standard for SDSs. As the new SDSs become available, they will be posted on our site. The requirement for manufacturers is to have the SDSs updated by 2015. We will be making every effort to have updates prior to 2015. Below is information from OSHA’s website (http://www.osha.gov/dsg/hazcom/hazcom-faq.html) regarding the timeline as well as why training must be conducted for employees prior to the compliance date.
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.
Q. Why must training be conducted prior to the compliance effective date?
A. OSHA is requiring that employees are trained on the new label elements (i.e., pictograms, hazard statements, precautionary statements, and signal words) and SDS format by December 1, 2013, while full compliance with the final rule will begin in 2015. OSHA believes that American workplaces will soon begin to receive labels and SDSs that are consistent with the GHS, since many American and foreign chemical manufacturers have already begun to produce HazCom 2012/GHS-compliant labels and SDSs. It is important to ensure that when employees begin to see the new labels and SDSs in their workplaces, they will be familiar with them, understand how to use them, and access the information effectively. For more information, http://www.osha.gov/dsg/hazcom/effectivedates.html.