There are 4 key compliance dates related to OSHA’s adoption of GHS:

December 1, 2013:

Employers must train employees on how to read GHS formatted labels and safety data sheets. (The intent of this tiered roll-out is to train the employees in advance so they can recognize the new labels and 16 section SDS before the manufacturers, distributers, and importers start generating and distributing them and/or introduce them to the workplace).

June 1, 2015:

Chemical manufacturers and distributors must complete hazard reclassification and produce GHS styled labels and safety data sheets. Distributors get an additional 6 months to complete shipments of old inventory.

December 1, 2015:

Distributors must comply fully with HCS requirements. (Grace period for shipments of old inventory ends.)

June 1, 2016:

Employers must be in full compliance with revised HCS, including complete training of employees on new hazards and/or revisions to workplace hazard communication program.

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