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New GHS/HAZCOM Enforcement Guidence

As you should be aware by now, the USA is transitioning over to the new Global Harmonization System/Hazardous Communication Standard. (GHS/HAZCOM) This new standard is designed to bring the US onto the same system used by other members of the UN and global community.  It includes new standards on Safety Data Sheets, labels, and placards/symbols.  The changeover period is a 4 year transition starting in December 2012.  Unfortunitly, durring this transition period, there has been some questions on what standards OSHA will inforce durring an inspection.  In june this year, OSHA finnally clarified this by issuing a new directive for the enforcement of the new GHS standard. To summarize, during the transition period to the new 2012 GHS standard, the goal is to establish consistent policies and procedures to ensure uniform enforcement of the hazard communication standard. It also provides inspectors with a detailed review of the areas they will be inspecting, including revised hazard classification of chemicals, standardizing label elements for containers of hazardous chemicals, and specifying the format and required content for safety data sheets, and how chemical users should manage their MSDS/SDS library. MOST IMPORTANTLY, it states that inspectors can use both the old standard, and the new standard to issue violations.  If you need a copy of this directive, email me at

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