December 1, 2015 is an important date. You should know why by now!
Dates are important to everyone – especially during holidays when people take time off, relax, and enjoy company. December 1, 2015 is definitely an important date – to those in the hazardous materials industry – but, there won’t be any time off, relaxation, or holiday to celebrate. Rather, today is the effective completion date for compliance with all modified provisions of the Hazcom 2012 final rule: distributors shall not ship containers labeled by the chemical manufacturer or importer unless it is a Hazcom 2012 label.
Sounds simple enough, right? Just put a Hazcom 2012 label on containers and you’re done. On the surface it sounds simple; however, it is anything but that. This affects chemical manufacturers, importers, distributors, and employers. If labeling is not part of the normal procedures then making sure the proper Hazcom 2012 label is used can be a daunting task.
Chemical distributors who package product (i.e., drums, totes) will need safety data sheets (SDSs) and labels updated. Otherwise, they cannot ship product as of December 1, 2015. Chemical distributors who distribute only (i.e., warehouse chemicals and distribute in the containers they came in) will need to find a way to re-label product before shipping or risk penalties if the labels are not updated. Industrial supply companies selling products such as cleaning agents, degreasers, solvents, or chemicals for industrial use will need to find a way to re-label product before shipping or risk facing citations if the labels are not updated. Re-labeling could mean opening up cases/skids of product, taking containers off, removing old labels, applying compliant GHS labels, and then packaging them up again – no small task.
There are ways that companies can get things in compliance.
Such things include:
- Ensuring proper label text appears on all product labels
- Designing artwork for new labels
- Ensuring SDSs are compliant to Hazcom 2012 requirements
- Producing labels in-house using software and printers
- Finding a label supplier to outsource label printing, or purchase printers and supplies
- Training employees, supervisors, and SDS authors to understand and apply the requirements of Hazcom 2012
- Referencing regulatory publications related to Hazcom 2012
Don’t be scared of this important date. There’s a lot of work involved in getting a simple label onto product containers, but in the end, the thing to celebrate is being in compliance with Hazcom 2012 and avoiding penalties. Get in touch with ICC Compliance Center at 888.442.9628 in the US, or 888.977.4834 in Canada to find out how we can help you with all your Hazcom 2012 compliance needs and more.