WAXIE Sanitary Supply is your trusted partner for ongoing resources, compliance training and support.
WAXIE and our Manufacturer Partners have been in the process of updating packaging, case labeling, and Safety Data Sheets (formerly known as Material Safety Data Sheets) for all chemical products to comply with the Globally Harmonized System of Classification and Labelling of Chemicals (GHS)
These modifications to the Hazard Communication Standard (HCS)
are being mandated by the Occupational Safety and Health Administration (OSHA)
, and will allow for an internationally standardized approach to hazard communication and classification. As part of our ongoing efforts to keep you informed on the transition to GHS, here are some updates on what to expect from WAXIE in the coming weeks and months:
GHS Timeline Recap To Date
As a reminder, this move toward GHS standardization started several years ago, and the recent deadline of December 1, 2015 is just the next step in a transition process to full GHS compliance on June 1, 2016.
To recap the GHS timeline to date, all employers were responsible for training their employees on the new GHS format by December 1, 2013, and WAXIE was pleased to have made training reference materials and resources available for our customers to help satisfy the requirements to meet this deadline.
Next, all manufacturers were responsible for shipping chemical products with GHS-compliant labels to distributors effective June 1, 2015, and then manufacturers and distributors were responsible for providing GHS-compliant SDS to end users by June 1, 2015 – and WAXIE has worked diligently with our manufacturer partners to meet these deadlines as well. Please note that WAXIE always posts new SDS online as soon as they are received from the manufacturer, and a copy of the new SDS is then printed and shipped to our customers on their next shipment of that product.
December 1, 2015: Updated Product Labels for Chemicals
The most recent deadline is December 1, 2015 when distributors are responsible for shipping products with GHS-compliant labels to end users. New labels have been designed for each product to correspond with the revised SDS, and these new labels have been phased in to inventory over the course of the past several months, with the transition scheduled to have been ongoing through December 1.
While you may have already begun to receive shipments of products with the new labels, over the course of the last several months you may have also received shipments with a combination of products with the “old” HCS-1994 labels you are used to seeing along with products with the “new” HCS-2012 GHS-compliant labels. The reason there has been some mixture of both HCS-1994 and HCS-2012 labels during the transition is that there was pre-existing inventory of HCS-1994 labeled products that were provided to WAXIE by its manufacturers, and the OSHA standard has made allowances for this product to continue to be sold as upstream suppliers work to revise their container labels.
Please note that the time period between June 1 and December 1 was meant to allow for a transition of inventories of the “old” labels to the “new” labels, and after December 1 only GHS-compliant labels are scheduled to be shipped, provided they have been made available by our manufacturer partners. WAXIE has been diligently working with its upstream manufacturing partners to manage this inventory transition, and appreciate our customers’ patience and understanding as we navigate this conversion while also making sure we do not run out of products to fulfill our customers’ needs.
Some notable exemptions to the GHS labeling requirement include products in the following categories:
- Hard surface disinfectants and sanitizers: the labels for these products are exempt from GHS and will not change since FIFRA labels approved by EPA preempt OSHA label requirements
- Hand sanitizers and antibacterial soaps: the labels for these products are exempt from GHS and do not have to change pursuant to FDA regulations
- Cosmetics and hand soaps: the labels for these products are also exempt from GHS and do not have to change pursuant to FDA regulations
- Consumer products: the labels for these products are also exempt from GHS and do not have to change pursuant to CPSC regulations
Please note that each of these product categories will still require a GHS-compliant SDS, which will be provided by WAXIE both online and with a customer’s first shipment after an SDS has been revised.
Ongoing through June 1, 2016: Implementation of HCS 2012
The final published deadline
for the GHS transition is June 1, 2016
when all employers with employees who use chemicals in the workplace need to be in full compliance with the new GHS requirements. That means making necessary updates to your Hazard Communication program, updating all SDS and product labels for chemicals being used onsite, and providing updated employee safety training.
To supplement this HCS information, OSHA has also published an instruction to communicate the policies and procedures of the Hazard Communication Standard (HCS 2012) in order to ensure a uniform enforcement once the standard has been fully implemented in 2016.
Of note, the following information is communicated in the aforementioned OSHA Instruction, Directive Number CPL 02-02-079, Effective Date July 9, 2015:
- Transition Period Through June 1, 2016: “Transition Period, May 26, 2012 – June 1, 2016. Employers are required to comply with either HCS 1994 or HCS 2012 or both during the transition (or implementation) period.”, page 80 of the instruction document.
- Ability To Have Both HCS 1994 and HCS 2012 Labels Concurrently Moving Forward: “On or After June 1, 2016. The employer may maintain shipped containers with HCS 1994-compliant labels. However, the employer must ensure that employees understand the differences between the HCS 1994-compliant labels and HCS 2012-compliant labels, and the lack of pictograms, signal words, etc., does not mean the chemicals may not present the same hazards.”, page 82 of the instruction document.
WAXIE will continue to provide updates related to GHS as they become available, and additional information about compliance dates may also be viewed on the OSHA website
What are my responsibilities as an employer to be in compliance with GHS?
- Employers are responsible for ensuring that employees know and understand the hazards associated with chemicals being used in the workplace. To accomplish this task, employers should take the following steps:
- Learn the Hazard Communication Standard 2012, and identify responsible staff
- Prepare and implement a written Hazard Communication Program
- Ensure all containers are properly labeled
- Maintain Safety Data Sheets
- Inform and train employees
- Evaluate and reassess program
Do all products need to have a new GHS-compliant Safety Data Sheet (SDS)?
Yes. All chemicals being used in the workplace should have an associated SDS to help workers know and understand the potential hazards. It is also advisable to maintain any associated MSDS on file for any chemicals purchased prior to GHS transition.
What is the difference between a new SDS and an old MSDS?
The most obvious difference is that one document will be called a Safety Data Sheet (SDS) and the other document will be called a Material Safety Data Sheet (MSDS). The other aspects to look for are that an SDS will have sixteen sections, while an MSDS is more likely to have fewer sections (typically between eight and twelve). Finally, an SDS will potentially also have a pictogram (or pictograms) and a signal word of either “Warning” or “Danger” to identify potential hazards.
Do all products need to have new GHS-compliant labels?
No. Products which are classified as hard surface disinfectants and sanitizers, hand sanitizers and antibacterial soaps, cosmetics and hand soaps, and consumer products are regulated by other agencies (such as EPA, FDA and CPSC) and are exempt from GHS labeling requirements.
What is the difference between a “new” GHS label and an “old” label?
The most noticeable differences are that a new label will most likely have a pictogram (or pictograms) and a signal word of either “Warning” or “Danger” to identify potential hazards. However, not all products contain materials which will trigger the need for a pictogram or signal word – one prominent example is WAXIE’s line of Bioactive Products, which do not contain any hazardous materials which require a pictogram or signal word.
Do all “new” GHS labels have pictograms and signal words?
Not necessarily. Only products which contain materials in sufficient quantity to pose a potential hazard are required to include a pictogram and signal word.
What if I have both “old” label product and “new” label product in my facility after the December 1, 2015 deadline?
It is OK. As long as employees understand the potential hazards presented by the chemicals being used at their workplace, it is acceptable to maintain inventory of both “old” HCS-1994 labeled products along with “new” HCS-2012 labeled product. It is recommended that the “old” labeled product be rotated to the front of the inventory so that it can be used first.
What if I have both “old” label product and “new” label product in my facility after the June 1, 2016 deadline?
It is OK. As long as employees understand the potential hazards presented by the chemicals being used at their workplace, it is acceptable to maintain inventory of both “old” HCS-1994 labeled products along with “new” HCS-2012 labeled product. It is recommended that the “old” labeled product be rotated to the front of the inventory so that it may be used first.
Should I seek to return “old” label product in an attempt to prepare my facility for June 1, 2016 deadline?
It is not necessary. A facility may maintain inventory of both “old” and “new” labels going forward provided training has been provided to employees so they will know the difference between the two labels, and they are able to understand the potential hazards presented by the chemicals. It is recommended that “old” labeled products be rotated to the front of inventory so that they may be used first.
WAXIE – The Most Trusted Name in Clean. Since 1945.
WAXIE is committed to working with our customers to help them comply with GHS requirements, and we are committed to working with our manufacturer partners to continue to manage the conversion process – we thank our customers very much for their business, and for their ongoing trust in us to be their partner as we work with them to successfully navigate this transition.