There is a great deal of confusion and some panic over the June 01, 2015 deadline for Hazcom 2012 compliance. Listed below are a few facts that may clarify your responsibilities:
- Who does the June 01 deadline really apply to? The June 01, 2015 OSHA deadline ONLY applies to manufacturers of chemicals and products requiring an (m)SDS. Only the original author of the (m)SDS needs to comply with this deadline. If you are an employer managing (m)SDS records from your suppliers so that your employees have access to them, this deadline does not apply to you.
Please click: OSHA Letter of Clarification. - What about chemical distributors? Distributors who buy chemicals from chemical manufacturers and then resell them to you have until December 01, 2015 to stop sending out the old MSDS format sheets and labels and only supply the new SDS format sheets and labels. Therefore if you are thinking of updating your collection to the most recent version, you may wish to consider holding off until 1st or 2nd quarter of 2016, because by then it is reasonable to expect that manufacturers and distributors are only sending the new SDS versions.
- What about chemical “blenders” who need the revised SDS from the manufacturer to re-issue their SDS? OSHA has issued some clarification for this. If you are the author of an (m)SDS and you want to meet the June 01 deadline, but are having difficulty because you can’t do so until you receive an updated SDS from your upstream suppliers, OSHA may use “discretion” regarding enforcement if you have shown that you have made a reasonable effort to obtain the revision, kept records of your attempts, researched alternate suppliers, etc.
Please click: OSHA Clarifies June 01, 2015 Hazcom Deadline for Chemical Blenders. - What about secondary container labels? If you currently use secondary container labels you have until June 01, 2016 to switch to the new SDS format. To assist, we recently launched www.SDSLabels.com. It is free to existing clients and $199 per year to everybody else. You log in to the web based service and create your own SDS/GHS secondary container label and then print it on a standard Avery peel and stick label template on any inkjet printer.
Please click: www.SDSLabels.com
Effective Dates
The table below summarizes the phase-in dates required under the revised Hazard Communication Standard (HCS):
| Effective Completion Date | Requirement(s) | Who |
| December 01, 2013 | Train employees on the new label elements and safety data sheet (SDS) format. | Employers |
| June 01, 2015
December 01, 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 01, 2016 | Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards. | Employers |
| 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 |