Enhesa Flash 72 September 2013 Issue | Page 21

Deadline to train workers on OSHA’s revised HCS adopting GHS Downstream users of chemicals should be aware that 1 December 2013 marks the first deadline to train employees on new labels and Safety Data Sheets (SDS), according to OSHA’s revised Hazard Communication System (HCS), which adopted the Globally Harmonized System of Classification and Labelling of Chemicals (GHS). Companies must train workers so they understand hazard symbols, warnings and information about chemicals. Care should be given to explain the order of information on SDS and how workers can obtain and use information. Worker understanding is vital to an effective HCS, but the UN GHS publication does not contain worker training requirements. OSHA has not amended the old HCS training requirements, contained at 29 CFR 1910.1200(h), except to reference revised classification and hazard communication. Under OSHA requirements, at a minimum workers must be trained about potential hazards as classified in the work area, methods to detect hazards, protections from hazards and understanding the hazard communication system. As the first federal deadline approaches, make sure to monitor state agencies that are adopting the HCS into state law, as it sometimes comes with different or additional requirements. Here are some examples: ? Washington has extended the deadline for worker training to 1 June 2014 ? Maryland has an outstanding proposal to adopt the HCS while extending requirements for labels and safety data sheets to wood and wood products. In addition, don’t miss opportunities to be proactive and learn more. At the state level, agencies are hosting workshops to assist with HCS compliance, which could benefit your training process, your company’s compliance initiatives and relationships with state agencies. Enhesa frequently monitors these issues through Enhesa’s Monitoring Service. To learn more, contact us at [email protected]. - Riaz Zaman, EHS Regulatory Consultant Enhesa Flash September 2013 | 21