GHS and OSHA's Evolving Hazard Communication Standard

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April 30, 2012 - James Lee

The last few weeks have been very exciting for us here at 3E.  After much waiting and anticipation, OSHA published its new Hazard Communication Standard 2012 in the Federal Register, aligning the old HCS with GHS and ushering it into a new era.  After we had digested the 800+ page final rule, it became very clear that the final rule will affect millions of workplaces and have a profound effect on the supply chain.

HCS 2012 introduces a set of criteria for classifying human health and physical hazards, as well as OSHA-defined hazards and hazards not otherwise classified (HNOC), which has far-reaching implications for the data contained within Safety Data Sheets (SDSs) and product labels. Many companies will need to reclassify their hazardous materials and capture additional data for publication on labels and SDSs. In many instances, SDSs and labels will need to be re-authored to conform to the new guidelines set forth in HCS 2012.

Achieving conformance will be a very complex undertaking for many companies, and we strongly advise affected companies to begin executing their compliance initiatives if they have not already done so.

If you are looking for more information on GHS, I recently presented a SOCMA webinar on OSHA, GHS and Product Stewardship Implications. During the presentation, I outlined the scope of HCS 2012, and explored the impact of the Standard both upstream and downstream.  I also offered attendees practical guidance on how they could prepare for the first deadlines.

How is your company preparing for HCS 2012?  Drop us a line below and let us know which initiatives you are prioritizing.

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