New SDS Requirements
Hazard Communication Revision Compliance Timeline & SDS Changes:
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