Youve still got to maintain your safety data sheet library, keep your workers informed and stay up-to-date with regulations, he said. With that in mind, he outlined what a companys HazCom priorities should be going forward.

First, make sure youre actually GHS compliant. By now, you should have a GHS SDS for every hazardous chemical on site, Russie stated. This includes not only your products, but your suppliers products as well. Since as many as one-half of all workplaces are still not fully GHS compliant, chances are good that companies have a few old material safety data sheets in their files.

If you still havent converted all of your sheets to the new format, you obviously should get on that as soon as possible, he cautioned. If one of your suppliers hasnt provided up-to-date documents yet, the onus is on them to fix it. But you should consider reaching out to delinquent suppliers even though you dont technically have a legal obligation to do so. Taking the initiative may solve the problem on its own, and also looks good to an inspector.

Second, continue HazCom training. The deadline for GHS HazCom training passed years ago, but a GHS training program of some kind remains a necessity, Russie said. New hires will have to be taught, and existing personnel need refresher courses every once in a while. He warned that inspectors will test workers knowledge of the HazCom system, so its important to keep it fresh in their minds.

Third, keep the HazCom management plan updated. If youre serious about staying in compliance, youve got to have a plan for keeping the HazCom system current, Russie noted. Your HazCom management plan should include a process for updating and distributing your SDSs. The plan should also include periodic refresher courses for employees, just to make sure they dont get rusty.

A HazCom management plan will have to change over time because it is likely that standards will change fairly often from now on. The UN releases an update to GHS every other year, and will release version 7 next year. Various countries use different versions of the UN system and will likely update them at some time. HazCom is an ongoing obligation, not just a one-time inconvenience. Keep on top of HazCom requirements, and stay in compliance, Russie cautioned.

With the final GHS compliance deadline nearly four months old, every company is expected to be in perfect compliance with the new standard. Noncompliance will be more costly than ever before, and to avoid fines companies should ensure they meet every GHS requirement. These requirements include updated SDSs, chemical inventory lists and container labels.

In a separate blog, Russie reviewed a companys training obligations. GHS training might seem like old news, he said, but many employers have failed to keep up with their training obligations. These employers saw the training deadline as a one-time obstacle rather than an ongoing project. If you havent given your workers a refresher course in GHS, you might already be out of compliance.

Every employee is expected to be able to recall the basic elements of GHS. Inspectors usually test them by asking some simple questions about the HazCom plan. If you dont think your employees will pass this kind of inspection, you should take that as a cue to schedule more training, Russie warned.

He then related some common practices to follow to shore up a GHS training regimen. For example, some employees were either never given or have forgotten large portions of their basic HazCom training. Without this background knowledge, they find it very difficult to put GHSs changes into context. To avoid this problem, make sure your personnel know the rudiments of HazCom before moving on to the details.

GHS has a lot of rules that can be difficult to fully memorize, Russie said. Without regular refresher classes, your employees might forget portions of their training. To ensure that training is retained, schedule refresher sessions every year or so.

If you follow these tips, you should be able to get the most out of your HazCom training program, Russie concluded. Hold a thorough refresher course every 12 to 18 months, and make sure your employees have references available if they want to look something up on their own.

Patrick Russie is a workplace hazard communication expert at Quantum Compliance, Ann Arbor, Michigan, U.S. Contact him at info@usequantum.com.