OSHA HazCom December 1 Deadline

Will you have completed training?  And, are you ready for the “Ripple Effect?”

By now, most companies are aware that the OSHA Hazard Communication (HazCom) standard was changed in 2012, and that the first compliance deadline is December 1, 2013.  By that date, employers must have completed training on the new label elements and the new safety data sheet (SDS) format.

Because manufacturers and suppliers are already using the new safety data sheet format, OSHA requires training to be completed so that workers can understand the new labels and SDSs.  Further, any company that creates its own SDSs will have to consider when it wishes to revise them, for example, over time as products or other information change, or “all at once” as a one-time effort.

After December 1, 2013, OSHA inspectors will be looking to confirm that training has been completed.  However, the “ripple effect” of the training requirement will mean, for many companies, that they will want to revise substantive statements in their HazCom plan and training program descriptions now, for clarity and accuracy, for example, to conform to the new labels and SDS format.  Although the deadline for revising HazCom plans does not apply until June 1, 2015, employers should consider whether to make such changes now, as a matter of efficiency and consistency, and to reflect the completed training. 

We have already assisted some employers in revising or developing SDSs under the new format, and, in a number of cases, have assisted clients in revising their HazCom plans and training programs descriptions to ensure they will comply with the new OSHA standard. 

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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