HCS 2012, Are you prepared for the next compliance date?

September 29th, 2014

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In 1983 the Occupational Health and Safety Administration (OSHA) published the Hazard Communication Standard (HCS) addressing hazardous chemical safety in the workplace.  The intent of the HCS was to provide workers with the “right-to-know” about the identities and hazards of the chemicals they work with, and have potential exposure to, during their jobs. From an employer standpoint compliance with the HCS may take a good amount of time and effort, but ultimately helps provide and maintain a safer workplace for employees.

In 2012 OSHA published the revised HCS (HCS 2012) which aligned the existing standard with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) which was used internationally.  The revised standard still requires employers to:

  • Maintain a written Hazard Communication program
  • Ensure containers are properly labeled
  • Provide access to safety data sheets (formerly material safety data sheets or MSDSs)
  • Ensure that employees are informed and provided training on chemicals in the workplace

The revised standard does require some significant changes to container labels and safety data sheets, such as the inclusion of pictograms and a signal word, and requires all safety data sheets (SDSs) to be of a consistent 16-section format.

The revised standard allows for a multi-year transitional period for compliance for manufactures and distributors of hazardous chemicals, and for employers covered by the standard. Initially a compliance date of December 1, 2013 was set for employers to complete all training for affected employees regarding the new label and SDS requirements. Compliance with the provisions for preparation of new labels and safety data sheets is required by June 1, 2015, although chemical distributors have until December 1, 2015 to distribute containers with pre-HCS 2012 manufacturers’ labels in order to accommodate materials received from the manufacturers close to the June 1, 2105 labeling compliance date. Finally employers will then have until June 1, 2016 to update their hazard communication programs and internal workplace labeling, if applicable.

With the December 2013 GHS training deadline past, companies should be in the process of obtaining updated HCS 2012 compliant SDSs for the chemicals in their workplace, ensuring that the distributors they use are on target with the labeling compliance deadlines, and begin updating their written Hazard Communication plans to reflect the new requirements.

CEA Inc. can assist organizations in the management of their Hazard Communication program and the transition to the new HCS 2012 requirements. CEA offers hazard communication training, SDS management and written program development tailored specifically to any organizations needs.

For more information on these services, please contact Scott Soucy, CIH, Health, Safety and Compliance Manager at 508-835-8822, email: ssoucy@cea-inc.com.

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