The final GHS deadline was back in June, but that doesn’t mean employers can ignore HazCom from now on. On the contrary, it’s just as important as ever for companies to keep their HazCom Management program going strong. You’ve still got to maintain your SDS library, keep your workers informed, and stay up-to-date with regulations. With that in mind, what should your HazCom priorities be going forward?
Make Sure you’re Actually GHS Compliant:
By now, you should have a GHS SDS for every hazardous chemical on site. This includes not only your products, but your suppliers’ products as well! Since as many as half of all workplaces are still not fully GHS compliant, chances are good that you’ve got a few old MSDS kicking around.
If you still haven’t converted all of your sheets to the new format, you obviously should get on that ASAP. If one of your suppliers hasn’t provided you with up-to-date documents yet, the onus is on them to fix it. You should consider reaching out to delinquent suppliers even though you don’t technically have a legal obligation to do so. Taking the initiative like that may solve the problem on its own, and also looks good to an OSHA inspector.
Continue HazCom Training:
The deadline for GHS HazCom training passed years ago, but a GHS training program of some kind remains a necessity. New hires will have to be taught HazCom, and existing personnel need refresher courses every once in a while. OSHA inspectors will test workers’ knowledge of your HazCom system, so it’s important to keep it fresh in their minds.
Keep your HazCom Management Plan Updated:
If you’re serious about staying in compliance, you’ve got to have a plan for keeping your HazCom system current. Your HazCom management plan should include a process for updating and distributing your SDS. This plan should also include periodic refresher courses for your employees, just to make sure they don’t get rusty.
Your HazCom management plan will have to change over time, because it looks likely that HazCom standards will be changing pretty often from now on. The UN releases an update to GHS every other year, and will be releasing version 7 next year. The US GHS standard is based on version 3 of the UN system, and will likely be updated eventually.
Remember that HazCom is an ongoing obligation, not just a one-time inconvenience. Keep on top of your HazCom requirements, and stay in compliance.