Survey Finds Half of Companies Unprepared for OSHA's HCS and GHS Deadline

If your company hasn't completed OSHA's GHS requirements outlined under the revised Hazard Communications Standard (HCS), you're not alone.

In a recent study conducted by Actio Software Corporation, 50 percent of environmental, health and safety (EH&S) professionals who participated in an online survey indicated that their company has not completed the obligations outlined under OSHA's HCS alignment with the GHS. The survey, which was completed by 108 participants in April 2016, was designed to gain a better understanding of the readiness (or lack thereof) of organizational alignment with OSHA's HCS and the GHS.

Of the 50 percent of participants who claimed their company has not yet completed the GHS requirements, 48 percent estimate that it will take their company at least another 120 days to complete OSHA's HCS obligations. With the fourth and final GHS deadline now a recent memory, it's safe to say that the current number of GHS-compliant companies in the United States is far below what the administration envisioned when it decided to align the HCS with the GHS in March 2012.

The GHS Domino Effect
The fact that so many companies are now behind the proverbial GHS eight ball doesn't come as much of a surprise. Last year, despite a clearly stated June 1, 2015, deadline, many chemical manufacturers missed a key GHS deadline to comply with the new GHS format. It required them to update safety data sheets (SDSs) and labels by reclassifying chemicals according to the new GHS format. The failure to meet the June 1, 2015, deadline created a snowball effect that hindered downstream users from securing, and producing GHS-compliant SDSs and labels.

Even so, OSHA anticipated that some companies would miss the chemical reclassification requirement due date and introduced "Good Faith" efforts companies could make to avoid penalties, including documenting the "reasonable diligence" efforts made to obtain the information necessary to meet GHS compliance, as well as provide a specific timeline for when the company will be in compliance with the GHS.

And while OSHA's "Good Faith" step helped companies avoid citations, the repercussions of the missed GHS deadline by some are still being felt throughout the supply chain today.

According to the GHS Readiness survey, securing updated SDSs from vendors was identified as the single biggest challenge by 34 percent of the GHS-ready companies and by 30 percent of non-GHS-ready companies. Additional challenges non-GHS-ready companies identified included staff training (15 percent), SDS authoring (11 percent) and "Other" factors, such as "reviewing any new risks identified on SDSs to include on workplace labeling" and "classifying our chemicals within our SAP system to create proper labels."

Representatives who claimed their companies were in compliance with the GHS listed staff training (18 percent) as the second biggest challenge behind securing updated SDSs, with authoring new SDSs (13 percent) and finding a sufficient GHS labeling solution/provider tying for third.

Investing In the GHS
According to the United States Department of Labor, OSHA's HCS alignment with the GHS is expected to impact more than 40 million workers in more than 5 million workplaces across the United States. With this in mind, manufacturers, importers, and distributors have been responsible for updating their employee training, hazard communications plan, SDSs, and labeling system in order to make the GHS transition. In doing so, businesses from a broad range of industries have invested time, money, and resources in order to meet OSHA's updated HCS.

But where did companies spend the most money? And why? According to the GHS Readiness survey, the overall majority of respondents indicated that their company spent less than $50,000 (65 percent of GHS-Ready Companies vs. 75 percent of Non-GHS-Ready Companies) leading up to the June 1, 2016, deadline. As outlined in the survey, the majority of these investments were earmarked for EH&S management software, GHS labelling equipment, and third-party support services such as employee training and SDS sourcing.

With the majority of respondents citing the ability to secure updated SDSs from vendors the biggest challenge in making the GHS transition, it's not surprising that purchasing EH&S management software that helps secure, track, and maintain SDSs was the single biggest investment made by companies looking to comply with the GHS.

The GHS Big Picture
While there are certainly skeptics out there, like the 24 percent who believe that OSHA's alignment with the GHS will never have a positive impact on business, regulatory compliance is and continues to be a top concern for EH&S professionals.

With the overall majority (62 percent) of survey respondents listing regulatory fines and penalties as the biggest risk of failing to comply with OSHA's HCS, it appears that there are still many obstacles preventing companies from completing the transition to the GHS. Of these challenges, securing updated SDSs from upstream providers tops the list and has forced a fair share of companies to purchase SDS management software and hire third-party document sourcing companies.

The fact is, despite being a key component of OSHA's June 1, 2015, deadline, authoring and distributing GHS-compliant SDSs continues to be one of the primary hurdles presented by OSHA's HSC. As a domino effect continues, the inability to secure updated SDSs from upstream providers will impact a company's ability to produce secondary chemical container labels that are required in accordance with OSHA's June 1, 2016, deadline.

As a result, it's highly probable that industrial end users will continue working toward achieving GHS compliance long after OSHA's final GHS deadline.

Chris Carragher is the Communications Director for Actio Corporation, a leading SaSS provider of chemical management and regulatory compliance software designed to improve workplace efficiencies while protecting the health and safety of employees. For more information visit or call 866-522-8102.

Posted by Chris Carragher on Jun 02, 2016