1.
Accept that GHS is a Reality: This
has been a longtime coming; the final rule goes into effect May 25, 2012.
2.
Be on the lookout for GHS-Formatted
Safety Data Sheets: Ensure that font-line employees are on the lookout for SDSs
and know what to do with inbound ones.
3. Review
Written Hazard Communication Plan:
This is one of the first things OSHA asks during an inspection and needs
to be updated to account for changes with new GHS transition. Training is essential
as well.
4.
Update Written Chemical Inventory:
Written chemical inventory is an important part of the written plan. It is key to managing the churn of new/revised SDSs so know what chemicals are in your
facilities and have corresponding SDSs for each one.
5.
Manage the MSDS/SDS Churn: All U.S.
manufacturers and distributors must reclassify chemicals and create updated
SDSs and labels for downstream users. Downstream users, employers and managers
should prepare for the SDS churn and expect entire MSDS library to turn over in
a short amount of time.
6.
Get a label strategy: Compliant Hazcom
2012 labels on shipped containers have six mandatory elements – start thinking
about that and build a strategy.
7.
Start Planning for Employee Training:
Employees must know how to read and understand revised labels and SDSs by Dec.
1, 2013. The benefit to this is that they can serve as early warning system for employers since employees must be trained on the process of replacing MSDSs with SDSs and
must complete training on all updates by June 1, 2016. Employers
should start training as soon as possible.
8.
Talk to Vendors about GHS: Find out suppliers’ plans and timelines for
meeting GHS transition (manufacturers are June 1, 2012, and distributors are Dec. 1,
2015). The sooner vendors are compliant with HazCom 2012 the easier it will be
on everyone.
9.
Remember SARA Obligations: Facilities with obligations under SARA Title III may need
to provide new and updated SDSs and chemical inventory information to local and
state emergency-planning agencies.
10.
Use Available Resources: Simplify compliance by allowing experts to guide
you through the GHS transition. Utilize all available resources from OSHA,
suppliers, new sources, educational resources and more.
It was also mentioned that OSHA will retain the framework
of HCS. The only changes include provisions that need to be aligned with GHS.
This will maintain or enhance the level of protection provided by HCS.