If you’ve been tracking GHS timelines, you know today is a big day. December 1st marks the effective completion date for compliance rules stating distributors shall not ship containers labeled by the chemical manufacturer or importer unless it has a HazCom 2012 label.
Chemical distributors who package product are now required to provide an updated SDS and label with each shipment leaving the facility. And faced with an even larger task are chemical distributors distributing chemicals in the original containers they were received in, as each container must be re-labeled if the existing label isn’t GHS-compliant. In many situations this includes unpacking cases of product, removing old container labels, applying new GHS-compliant labels and repacking each product.
Unfortunately, concerns regarding the ability to deliver on this requirement hold strong as the predicted delay of SDS distribution from upstream manufacturers has proven true. Though thankfully, in preparation of this very challenge, OSHA released its February 29, 2015 memorandum providing enforcement guidance for those who demonstrate reasonable diligence and good faith. For all the distributors out there, here’s a quick refresher on the guidance OSHA provided:
For additional information regarding OSHA's enforcement guidance, view the memorandum here.
If you happen to have questions regarding GHS-compliant labeling, check out our GHS Community Labeling Q&A here.