Without any fanfare, December 1, 2013 came and went. No alarms went off, and quietly, the day dissolved. It was most likely a regular Sunday for you and your family.
What was significant about that day? It was the deadline set by OSHA to have every person in the U.S. who works with hazardous chemicals or waste — all 43 million of them — fully trained on the new Hazard Communication Standard, referred to as HazCom 2012. If this is news to you or if you have any doubt that you are fully up to speed, then it’s a good thing you’ve found your way to this article now. OSHA has chosen to base the updated standard on the GHS (Globally Harmonized System) created by the United Nations, requiring the use of the new system by 2015.
The timing of the training deadline, well in advance of the implementation deadline, reflects OSHA’s concern about the one of the most significant problems in American workplaces: during 2013, Hazard Communication violations ranked as the second most common OSHA citation. This year, the additional GHS training requirements could cause an influx of violations in Hazard Communication, moving it to the number one spot for 2014; on the other hand, the added attention brought by HazCom 2012, and the new training, may actually result in fewer Hazard Communication violations.
If your facility is in compliance, then you probably went through this training a few months ago and will avoid the costly OSHA violation fines. Records must be kept of all employees’ training, and must be provided upon request. Although OSHA compliance officers were not lined up outside facilities the week after December 1, 2013 to check that training had been completed, they could be gearing up to stop in sooner than you think. Last year, OSHA released information on their SST (Site-Specific Targeting) program for random inspections, and it is generally unknown if any of their targeting this year will involve HazCom 2012 training.
As of August 2013, many workers hadn't even heard of the changes, according to private sector hazardous waste communication consultants. Not being fully trained on HazCom 2012 at this point is an expensive oversight, with costs up to $7,000 per violation, per person. If your facility is not up to compliance, then you need to act fast.
The required training covers understanding the labeling elements and Safety Data Sheet (SDS) format that are consistent with GHS. Realize that this will be an ongoing effort, with periodic retraining for existing employees as well as fresh training for new hires.
Lucky for you, we have the perfect handy guide for you to distribute to your employees. Our wallet-sized GHS quick reference cards have everything your employees need to know about the GHS label elements. Additional training can be found here, or through our HazCom 2012 guide that you can order for your facility.
If you really want to stay ahead of the game, you can start using the new labels before the deadline hits. Print them at your facility using a DuraLabel printer, which comes with OSHA-compliant DuraSuite software, including templates and an editable database for HazCom 2012 and GHS format labels.
If you have any questions, feel free to contact our knowledgeable support specialists, who are more than happy to help make sure that you're not one of the facilities left behind on training. Call 1.888.326.9244 to get all the information on the GHS label elements for your workplace.