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Tracy Kosbau
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OSHA Training Requirement Deadline Dec. 1
Notify employees of new elements on Safety Data Sheets

WRA recently learned that the Occupational Safety and Health Administration (OSHA) has revised Hazard Communication Standards (HCS) pertaining to properly labeling hazardous chemicals. There are training requirements for employers and the first deadline for training is Dec. 1, 2013

Essentially, the goal is to give employees worldwide a better understanding of the hazards associated with chemicals in the workplace through the use of more consistent definitions and standard pictograms.

Major Hazard Communication Standard changes

  • Hazard classification: Provides specific criteria for classification of health and physical hazards, as well as classification of mixtures.
  • Labels: Chemical manufacturers and importers will be required to provide a label that includes a harmonized signal word, pictogram, and hazard statement for each hazard class and category. Precautionary statements must also be provided.
  • Safety Data Sheets (SDS): (formerly known as Material Safety Data Sheets or MSDS) SDSs will now have a specified 16-section format.
  • Information and training: Employers are required to train workers by December 1, 2013 on the new labels elements and safety data sheets format to facilitate recognition and understanding.

All employers using hazardous chemicals in the workplace must comply with the changes made to the SDS--including the new specified 16-section format--and should be aware of OSHA’s training expectations and strategies for meeting the Hazard Communication Standards.

For more information on the new rule, OSHA has put together a fact sheet outlining the changes and additions.


  • Dec. 1, 2013 – Employers must train all employees on the new label elements and the SDS format. (It’s a good idea to document the date of training and employee participation).
  • June 1, 2015 – Chemical manufacturer, importers, distributors and employers must comply with all modified provision of the revised HCS (with this exception – distributors may ship products labeled by manufacturers under the old HCS until 12/1/15).
  • June 1, 2016 – Employer must update alternative workplace labeling and hazard communication programs as necessary by this date. They must also provide additional employee training for newly identified physical or health hazards.

Why is there is a training deadline prior to the full compliance deadline?

OSHA is requiring that employees are trained on the new label elements (i.e., pictograms, hazard statements, precautionary statements, and signal words) and SDS format by December 1, 2013, because they believe that American workplaces will soon begin to receive labels and SDSs that reflect the new standards, since many American and foreign chemical manufacturers have already begun to produce HazCom 2012/GHS-compliant labels and SDSs. It is important to ensure that when employees begin to see the new labels and SDSs in their workplaces, they will be familiar with them, understand how to use them and access the information effectively.

Want to understand this issue without having to read through multiple fact sheets? This OSHA YouTube video provides a quick overview.

How do I train my employees?

To assist in employee training OSHA has a Fact Sheet on training requirements and has created “Quick Cards” on the following topics (in both English and Spanish) that you can post in the workplace and/or distribute to employees:
Safety Data Sheets

Since the deadline is rapidly approaching, WRA recommends scheduling a staff meeting and distributing copies of the "Quick Cards."

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Wisconsin Restaurant Association • 2801 Fish Hatchery Rd. • Madison, WI 53713 • Tel: 608.270.9950 • Toll Free: 800.589.3211 • FAX: 608.270.9960