December 1, 2014 marks one year from the date that employees were to be trained in OSHA’s addition of the Globally Harmonized System for Hazard Communications to its Haz Com Standard.  Have all of your employees received training?  Yes, it was a bit premature of OSHA to require training by the end of 2013 for something that wasn’t required until mid 2015.  Now that we are less than a year away from implementation of major requirements, it makes sense to train your employees now.  If you provided training early in 2013, you should consider providing refresher training.

We expect that manufacturers of hazardous chemicals will soon begin labeling their products using the required text and pictograms, and to release new Safety Data Sheets (SDSs).  A year ago I spoke with an OSHA Compliance Safety and Health Officer who noted that she was beginning to see consumer products with pictograms on the labels. Since then there has not been a great increase in labeling and the publication of SDSs.  In fact a search of major companies websites shows that, in many cases, MSDSs have yet to be replaced with SDSs.

Most likely, companies have held off on new labels and safety data sheets until 2015 to incur costs relating to the changes closer to the time they are required to do so.  Prudently, they also want make sure they don’t have to respond to any last minute changes by OSHA.  That certainly makes good business sense. Since no last minute changes are anticipated, we can expect manufacturers and importers to begin moving to compliance during the first quarter of 2015.

Hazard Communications remains the number two most violated OSHA standard.  You can expect that citations will increase over the next few years.  Training is just one part of the program, but it is the one thing that is required as of today.  Make sure your employees understand OSHA’s changes to its Hazard Communications Standard.