As a result of revisions to OSHA’s Hazard Communication (HAZCOM) regulations in 2012, MSDSs and product labels are being changed to more closely align with international standards. As a result, OSHA has required employers to train their employees on the new labels and MSDSs (now referred to as Safety Data Sheets, or SDSs), no later than December 1, 2013. Employers should revise training materials to incorporate the new label and SDS formats, and should conduct, and document, training of employees by December 1. OSHA inspections after December 1 likely will check for compliance with the training requirements. While the deadline for revising employers’ HAZCOM programs is not until June 1, 2015, employers may go ahead and revise their programs at any time. Revision now may make sense in order to conform the HAZCOM program to employee training.
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