What if you failed to meet the OSHA’s December 1st GHS deadline

New GHS Labeling Compliance Date Upcoming

December 1, 2015, marked the OSHA or GHS deadline for hazardous chemical distributors.  According to regulations, after December 1, 2015, Globally Harmonized System imagehazardous chemical distributors may no longer distribute products out of compliance with GHS standards.  All outbound shipments must be GHS-labeled with GHS compliant safety data sheets (SDS) included.

Ideally, with this deadline, every hazardous material that ships out will feature GHS-compliant labels and SDS.  In reality however, many companies, manufacturers and distributors alike, are out of compliance and behind on meeting these mandatory deadlines.

Similar to the June 1, 2015 deadline for manufacturers, OSHA has stated that in situations where distributors are unable to obtain GHS compliant labels from upstream suppliers, documenting and showing “good faith” will help inspection claims.  A statement from OSHA is follows.

“After December 1, 2015, distributors shall not ship chemicals without HCS 2012-compliant labels. In the situation where a distributor’s supplier has not been able to comply with the June 1, 2015 compliance date despite reasonable diligence and good faith efforts, the distributor may continue to ship HCS 1994-compliant labels. The distributor must be able to document its communication with the supplier to determine the circumstances for the supplier’s noncompliance with HCS 2012.”

In the statement, OSHA further explains that distributors can potentially make this exemption claim up until December 1, 2017.

The final OSHA/GHS deadline is June 1, 2016, where all employers will need to be fully compliant with GHS and OSHA’s HazCom Standard.  HazCom was listed as the 2nd most cited OSHA violation again in 2015.  Check out our OSHA 2015 Guide for a review of the most important OSHA updates in 2015.


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