The June 15, 2015 effective date for chemical manufacturers, importers, distributors, and employers to be in compliance with the 2012 Hazard Communication Standard is rapidly approaching. There are only two exceptions stipulated in 29 CFR 1910.1200(j)(2)(i) and (ii).
By this effective date, chemical manufacturers, distributors, and importers are required to classify their chemicals in accordance with the revised 2012 standard, and develop Safety Data Sheets (SDS) and labels in compliance with the 2012 Hazard Communication Standard. Employers are then responsible for ensuring that the labels and SDSs are readily available to all employees. Employers are also responsible for training employees on how to properly recognize the hazards and how to handle the chemicals based on the hazards conveyed. Employees should be well accustomed to the revised 2012 GHS aligned classifications by now. Remember to archive older versions of MSDSs and SDSs as updated SDSs are received.
As of early 2015, OSHA has stated that manufacturers and product formulators of mixtures that can prove they tried to gain information from upstream suppliers unsuccessfully will be allowed a reasonable time period to come into compliance. In these cases, documented evidence of due diligence and a plan for obtaining compliance must be in place.