Mark your calendars! After December 1, 2015 chemical distributors may no longer ship inventory out of compliance with GHS regulations. OSHA did release a memorandum on May 29, 2015, that stated if distributors were able to show “good faith” in becoming GHS compliant with documented attempts, OSHA would show lenience with selective enforcement.
Keep in mind that as a distributor, you are not responsible for converting the MSDS you have in your database. MSDS conversions are the responsibility of the chemical manufacturer. However, don’t expect your supplier to send you new GHS compliant SDS sheets automatically. Upstream suppliers are only required to send their new SDS sheets for one of the following reasons.
- Request from downstream distributor
- New chemical shipment
- First chemical shipment after a change has been made
Additionally, although the June 1, 2015 deadline for manufacturers to convert their MSDS sheets into GHS compliant SDS sheets has already passed, many suppliers have not converted their MSDS sheets. Requesting your supplier for updated SDS sheets not only ensures your compliance, but also pressures your supplier to become compliant themselves, ultimately increasing overall industry safety.
After the upcoming December 1, 2015 deadline for distributors, June 1, 2016 is the final GHS deadline for workplace labeling and updating the HazCom program in the workplace. Any additional training for new physical or health hazards present in the workplace indicated on updated SDS must be completed by June 1, 2016. Protect your workers from potential hazards by raising awareness and protect your company from expensive OSHA fines by staying proactive in being compliant!
