CoatingsPro Magazine

MAY 2015

CoatingsPro offers an in-depth look at coatings based on case studies, successful business operation, new products, industry news, and the safe and profitable use of coatings and equipment.

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42 MAY 2015 COATINGSPROMAG.COM Safety Watch O n June 1, 2015, your responsibility for compli- ance to the Occupational Safety and Health Administration (OSHA)'s Hazard Communication Standard (HCS) will take a sharp turn as all employers in all business sectors will be required to be in full compliance with the changes to the existing standard and its align- ment with the United Nations' Globally Harmonized System of Classifcation and Labeling of Chemicals (GHS). Te HCS addresses the informational needs of both employers and employees with regard to using hazardous chemicals in the workplace. It is often referred to as the "Right-to-Know" law. Many benefts are expected from revising the HCS to be consistent with the GHS. If your company already has a hazard communication program that complies with the original HCS, you will have limited changes to make to ensure compliance with the revised standard. Under the original HCS, and continued in the 2012 revisions (aka HazCom 2012), you must prepare and implement a hazard communication program for your employees who are potentially exposed to hazardous chemicals in the workplace. By now, you must have trained your employees about the format and presentation of the new labels and Safety Data Sheets (SDSs) that they will begin seeing in the workplace this year. A ll new labels and SDSs must be available by June 1, 2015; however, if you order a product from a distributer after that date, you may still receive noncompliant labels until December 1, 2015. If you identify new hazards after December 1, 2015, due to the reclas- sifcation of the hazardous chemicals, you have until June 1, 2016, to ensure that they are included in the hazard communication program, the workplace labeling refects those new hazards, and employees are trained on any new hazards. Six Steps to Compliance To help you ensure that you're comply- ing with the new standards, the following six steps are recommended. 1. Learn the Standard and Identify Responsible Staf Review the actual provisions of the standard to ensure you are in full compliance. OSHA provides online access to the standard, as well as guidance, interpretations, and other relevant materials, on its hazard communication webpage: www.osha. gov/dsg/hazcom. As a contractor, the provisions that apply to your company simply using chemicals in the workplace, rather than those that produce or import chemicals, are found primarily in the following By now, you must have trained your employees about the format and presentation of the new labels and Safety Data Sheets (SDSs) that they will begin seeing in the workplace this year. By Jack Fearing, CPEA, Managing Partner of Fearing International Group LLC Keeping Compliant: OSHA's Hazard Communication Standard Changes HazCom 2012 Effective Dates Completion Date Requirements Who December 1, 2013 Train employees on new label elements and SDS format All Employers June 1, 2015 Comply with all mod- ified provisions of HazCom 2012 All Employers June 1, 2016 Update workplace labeling and HCS as necessary and complete additional training Transition Period* Comply with either existing HCS or HazCom 2012 All Employers *During the transition from current requirements to the new requirements, employers may comply with either the current OSHA standard or HazCom 2012, both of which require a hazard communication program.

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