In order to comply with OSHA regulations, corporations must implement GHS standards by June 1, 2015. This includes updated Safety Data Sheets (SDSs), labels, and hazard communication programs. Use this quick checklist to make sure that you’re compliant!
Are you aware of the pending deadlines?
SDS conversion deadline: June 1, 2015
Labeling deadline for manufacturers: June 1, 2105
Labeling deadline for distributors: December 1, 2015
Have all MSDSs been converted to GHS compliant SDSs?
The SDS is a 16-section document. Some of the new features of the GHS complaint SDS are pictograms, hazard statements, and precautionary statements. However, it’s also important to ensure that your SDSs are equipped with the revised chemical and hazard classifications.
Have you implemented an efficient, scalable labeling program?
Every item on the factory or storeroom floor containing a hazardous chemical and every shipment must be labeled with the precise guidelines based on the destination. Have you established and implemented a system to ensure that all new products?
Are all products, regardless of shape or size, updated with GHS compliant labels?
Drums, pails, cans, cartons, and even tiny vials must all be labeled with the designated GHS elements. In addition to the GHS label elements; information from alternative regulatory bodies (such as the Department of Transportation) needs to be clearly market. Although it might be challenging, it’s imperative to ensure that each label is equipped with the appropriate information.
Are your SDSs and labels in the correct language and format?
For each country that you export to, there are specific regulations and language requirements. It’s imperative that you confirm your SDSs and labels are in the correct country-specific template and language in order to ensure compliance!
Are you qualified for a deadline extension? Do you have documentation on the five requirements outlined in OSHA’s “Good Faith” memorandum?
1. Documented requests for information to upstream suppliers?
2. Developed efforts to find hazard information from alternate sources?
3. Provided a written account of the dialogue with upstream suppliers, including copies of all relevant communication?
4. Provided a written account of dialogue with distributors and dated copies of all relevant communication regarding why compliance is unattainable?
5. Have you implemented a course of action to make necessary changes?
We understand how challenging the conversion process can be, which is why we’re here to help! If you have any questions regarding your GHS complaint SDSs; give us a call at 734-930-0009, or send an email to SDS@usequantum.com with any questions or concerns. If you haven’t found a labeling solution that works for you, reach out to our partners at LabelMaster. Learn more about their services here: http://www.labelmaster.com/contactus/scripts/contact_us_main.cfm
Download and print the PDF version of this “to-do list” so that you can continue to reference it as we approach the deadline!
