Issue link: http://palletcentral.uberflip.com/i/507696
30 PalletCentral • March-April 2015 palletcentral.com requests for clarification (interpretative letters), so it announced in the guidance that it will "exercise its enforcement discretion" to allow a "reasonable time period" for manufacturers to come into compliance, as long as they have established "reasonable diligence" and "good faith efforts" in updating their SDSs and labels. The guidance also allows manufacturers and distributors who have been diligent an extension to ship products with the old-style labels and SDSs to downstream employers until December 1, 2017. For other manufacturers and distributors, the standard still requires GHS-compliant labels on any products shipped after December 1, 2015. The guidance also states that once an employer receives a GHS-compliant SDS for a hazardous chemical, it must maintain them and follow the other requirements in the 2012 final rule. While the labeling/SDS extension granted to some upstream manufacturers and distributors is good news for them, it may be bad news for employers who went ahead and did timely training but will now find that the training will not be put to use because the products they purchase do not include the new form SDSs, new labeling systems and new pictograms. As the saying goes when it comes to training, "use it or lose it." Employers will need to stay alert for when labels change on the products they commonly use, make sure that as new SDSs are received, they supersede the old ones in your binder, and that the new labels and sheets are reviewed with affected workers (both your own employees and any temporary employees in your workplace who also are exposed to the chemicals). Make sure that this training is documented as well, even if you already documented the initial GHS training done to meet the 2013 deadline. GHS is going to be a moving target for compliance for at least the next few years, but by being diligent, an employer can avoid being a target for OSHA enforcement! PC SAFETY The scope of the HazCom standard is quite broad and covers not only wood dust, but common chemicals like bleach, solvents, paints, lubricants and even cleaning products. Adele L. Abrams is an attorney and safety professional who represents companies in litigation with OSHA and also pro- vides safety training and consultation. The Law Office of Adele L. Abrams PC has three offices: Beltsville, MD; Denver, CO; and Charleston, WV. Adele can be reached at 301-595- 3520 or www.safety-law.com.