In May 25, 2012, the final rule for the updated Hazard Communication standard became effective and enforceable. OSHA published a transition schedule, and as of June 1, 2016 that transition is over.
The transition dates that affect IFCA Members is/was as follows:
December 1, 2013 - all employees were to be trained on the new labels and Safety Data Sheet (SDS) format
June 1, 2016 - Update alternative workplace labeling and Hazard Communication Program as necessary, and provide additional employee training for newly identified physical or health hazards.
If you have not trained your employees, and kept them trained on an annual basis you are already in violation and are subject to citations should an OSHA inspection happen. By the end of this month, you must have updated your written Hazard Communication Program (everyone is required to have one). There is no more transition period after that date. This is a service our Safety Director, Michael Brantley, can provide. For those Members who have completed the safety assessment and are eligible for the FREE safety services provided by IFCA, please reach out to Michael. For those Members who have not completed the assessment, this is something you need to handle immediately. Please call Michael to schedule a time for your safety assessment. Once completed, you can work together to complete your Hazard Communication Program.
For a complete list of Frequently Asked Questions, please visit the OSHA Hazard Communication page at: www.osha.gov/dsg/hazcom/hazcom-faq.html
Our Safety Director, Michael Brantley, can be reached at 954-298-6731 or michael@ifcassociation.com