OSHA has lifted a stay on enforcement regarding the provision to update labels when new hazard information about a particular chemical is available. Chemical manufacturers, importers, distributors or employers have six months to revise the labels after the information is received. All chemical labeling must be in compliance with the GHS standard by June 2016, but up until that date employers may comply with the old hazard communication standard, the new GHS standard, or both. 
Perhaps the party under the most pressure with the changes then is the chemical manufacturers, who are required to replace their existing product labels with ones that embrace the new format.
“Manufacturers have a lot of latitude in how they make [chemical label] descriptions but with the new standard it is much more prescriptive,” says Bill Balek, director of legislative affairs at the ISSA. “Before they re-label they have to reclassify their products. We’re using a different scheme of stratifying the products and they are very detailed.” 
Besides changing labels, the revised safety data sheets require information to be presented in a 16-section sequence. Before GHS, OSHA allowed either its eight-section format or ANSI’s 16-section format to be used. Now, the SDS will be similar to ANSI’s version with the requirement that the sections be presented in a strict order. Formerly, the document’s format was left up to manufacturers. 
The required order is as follows: Identification, Hazard’s identification, Composition/information on ingredients, First Aid measures, Fire-fighting measures, Handling and Storage, Exposure controls/personal protection, Physical and chemical properties, Stability and reactivity, Toxicological information, Ecological information, Disposal considerations, Transport information, Regulatory information, and Other information, including date of preparation or last revision. 
Casavant says he expects the changes to safety data sheets and chemical labels to present an ongoing challenge to employers over the next few years, as they attempt to bring their inventory into compliance. 
“I think it’s safe to say that folks are stressed,” says Casavant. “People are quite concerned about the workload this new standard will bring. [Employers] suspect some chemical manufacturers will take their time in complying and that will create issues for end users downstream.” 

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OSHA GHS Training Deadline is Dec. 1, 2013