Transitioning to the OSHA Globally Harmonized System: Is Your Company Prepared?
On March 20, 2012, OSHA issued the Hazard Communication Standard Final Rule (HCS 2012), one of the most significant regulatory changes to affect workplace health and safety practices in years. In the US, over five million workplaces and 40 million workers are expected to be impacted by this regulatory change.
The need for reform in HazCom regulations became clear as violations of the HCS made their way to the top ten lists of OSHA violations every year. To fulfill this need for change, OSHA built on the existing HCS by adopting the Globally Harmonized System of Classification and Labeling of Chemicals (GHS).
As we pass the first milestone of implementing the new system, is your company taking the necessary steps to ensure compliance?
December 1, 2013, marked the deadline mandated by OSHA for all employees to be trained on the new labeling elements and the standardized format for Safety Data Sheets (SDSs).
To ensure that you are on track, EHS Today recommends that your transition plan includes the following:
2. Chemical inventory
3. SDS updates
5. Project auditing
To further assist you in complying with this deadline, OSHA’s Fact Sheet provides the details of the training requirements.
Please note the following deadlines that are included in the 36-month GHS transition period:
To align with OSHA’s deadlines, beginning June 1, 2016, ISN Clients and ISN Review and Verification Services (RAVS) will only accept programs in compliance with the new elements of HCS 2012. Programs submitted prior to June 1, 2016 that reference outdated elements will need to be resubmitted at that time.
If your company’s program has been updated to be in compliance with the new HCS, please resubmit at your convenience by clicking “Yes, Submit New Program” on the Upload Document tab for the Hazard Communication – (HazCom) requirement in ISNetworld. If your company’s program in ISNetworld already addresses the new elements of the HCS and is at a “RAVS Verified” status, no further action is required.
If you have further questions about your HazCom program, please contact the ISN Customer Service Team at
+1 214 303 4900 or firstname.lastname@example.org.