On the first day of June of this year, the final Hazard Communication Standard deadline will take effect. As per the Occupational Safety and Health Administration (OSHA)’s ruling, all chemical substances must be properly labeled according to the 2012 HCS revision as well as the UN’s latest revision of Globally Harmonized System for Classification and Labeling of Chemicals.
Much of this work should have already been done before last year, as the official deadline for converting existing material safety data sheets (MSDSs) to new, compliant safety data sheets (SDSs). The new SDSs follow the standards laid out in the GHS system and have specific new hazard classification warning statements. They are also standardized in ways that previous MSDSs were not, with the hazard classifications, product information, and warning statements – among other key details – laid out in 16 set sections.
This year’s deadline is for the corresponding hazard classification labels. Information on a GHS-standardized label should mirror the information on the safety data sheet for any given chemical. However, making new labels and applying them directly to stored chemicals is much more difficult than simply printing off a new safety data sheet or storing it online in a cloud-based SDS management service like the one Quantum Compliance provides.
All chemicals stored prior to the GHS deadline in 2015 likely were not given compliant labels, and so every chemical stored needs to be checked. Not every chemical stored prior to June of 2015 will need an updated chemical hazard label, but all chemicals do need to have intact labels that reflect their owner’s most recent knowledge of the chemical’s hazard classification.
Chemicals that were not produced in-house but were instead shipped there are not required to undergo an update, even if they are labeled under HazCom 1994 instead of HCS 2012.