Planning for the transition period of 3 years for issuance of GHS compliant SDS & labels

OSHA has prescribed some effective dates for the transition of SDS and Labels to GHS standards. http://www.osha.gov/dsg/hazcom/effectivedates.html. By December 2013, companies must have trained staff on the new label elements and safety data sheet formats. OSHA offers a transition period of about 3 years for the issuance of fully GHS compliant SDS and labels.

While this sounds reasonable, it is important to note that OSHA categorically rejected the idea of adding the new GHS elements to the existing material safety data sheet format. Unlike the EU scenario, the introduction of GHS in the United States with its’ new symbols and new classification methods is very different from the previous ‘performance-oriented’ system, where hazards were assessed by the professionals. The concern for businesses now is that they don’t have the option of “blending” the old SDS information with the new GHS elements in the same document.

Companies are now faced with creating new documents that meet the GHS requirements, as well as training staff on the new label elements and SDS format. Within 3 years maximum from today, they need to phase-out all existing previously issued SDS documents and release their new SDS if they wish to continue selling products in the U.S market.

A second critical point made by OSHA, is the fact that once an SDS is released under the new GHS system, indicating the applicable hazard classes and categories, the container of the product being shipped with this SDS MUST be labelled with the GHS symbols, using the GHS classification and precautionary statements. This has a tremendous impact on when a company can actually start to issue the new GHS SDS, as they must also be ready to label their products, accordingly.