SAFETY DATA SHEETS
Safety Data Sheets The Hazard Communication Standard (HCS) is now aligned with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). HCS requires chemical manufacturers, distributors, or importers to provide Safety Data Sheets (SDSs) (formerly known as Material Safety Data Sheets or MSDSs) to communicate the hazards of hazardous chemical products. OSHA has provided deadlines for phasing in the regulation and is requiring retraining for workers on hazard communication. The new final regulation was published on March 26, 2012 and became effective May 25, 2012. OSHA defines the phase-in period deadlines of the revised Hazard Communication Standard as follows: – December 1, 2013 – Employers must train employees on the new labels and SDS format. – June 1, 2015 – Chemical manufacturers, importers, distributors, and employers must be in compliance with all modified provisions of the final rule, with the exception that as of December 1, 2015, distributors cannot ship containers labeled by a chemical manufacturer or importer without a GHS label. – June 1, 2016 – Employers must update alternative workplace labeling and hazard communication programs as necessary, and provide additional employee training for newly identified physical or health hazards. Chemical manufacturers and importers are responsible for sending the updated documents to the end users of their chemicals with the first shipment or the next shipment after a change has been made. This means suppliers can realistically update their libraries only as quickly as manufacturers and importers update their own safety data sheets. An OSHA memorandum dated May 29, 2015 allows distributors to continue to ship chemicals with HCS 1994 labels until December 1, 2015. Distributors must provide a HCS 2012-compliant label and SDS for each and every individual container shipped with any future shipments after December 1, 2015 or upon request, unless they can demonstrate reasonable diligence and good faith as discussed in this policy. Additionally, distributors must provide HCS 2012-compliant SDSs to downstream users with the first shipment after a new or revised SDS is provided by the manufacturer or importer.