Key Learnings as of November, 2016
12/1/2013: Employers must have trained employees on new label elements and safety data sheet format.
6/1/2015: Chemical manufacturers, importers, distributors & employers must be in compliance with all modified provisions of final rule.
12/1/2015: Distributors shall not ship containers labeled by the chemical manufacturer or importer unless it is a GHS label
6/1/2016: Employers must update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards.
During the transition period to the effective completion dates noted in the standard, chemical manufacturers, importers, distributors and employers may comply with either 29 Code of Federal Regulations 1910.1200 (the final standard), the current standard or both.
Please note that there may be varying requirements in the implementation schedule, etc. in those states with State OSHA Programs.