New SDS Requirements

Hazard Communication Revision Compliance Timeline & SDS Changes:

Effective Dates:

The below information summarizes the phase-in dates required under the revised Hazard Communication Standard (HCS): All chemical manufacturers, importers, distributors and employers must comply with either the revised 29 CFR 1910.1200 standard (HazCom 2012), or the current standard (HazCom 1994), or both.

December 1, 2013 – Employers:

Train employees on the new label elements and safety data sheet (SDS) format.

June 1, 2015 – Chemical manufacturers, importers, distributors and employers:

Comply with all modified provisions of this final rule.

Note: distributors may ship products labeled by manufacturers under the old system until December 1, 2015.

December 1, 2015 – Distributors:

The Distributor shall not ship containers labeled by the chemical manufacturer or importer unless it is an HCS Compliant label 2016.

June 1, 2016 – Employers:

Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards.

Chemical User Compliance Checklist:

• Train employees on new GHS-style label elements
• Train employees on new SDS format
• Continue to update safety data sheets when new ones become available
• Update written hazard communication programs if new hazards are identified
• Update hazard communication program as necessary
• Update alternative workplace labeling as necessary
• Provide additional employee training for newly identified physical or health hazards
• Make sure all container labels in the workplace are compliant