As of December 1, 2015, distributors will be required to ensure that all products shipped (and which are subject to the OSHA Hazard Communication Standard as revised by the GHS (HazCom 2012)) are labeled consistent with the GHS elements.

According to ISSA reporting, OSHA has decided not to extend the deadline. But it has issued a relaxed enforcement policy to its compliance officers with instructions to not enforce the Dec. 1, 2015 effective date in the following two situations:
    1.    The distributor is not able to comply with the labeling requirements due solely to the failure of the supplier to provide them with the necessary labels, and the distributor has exercised good faith efforts to obtain the information.
    2.    Products that are packaged for shipment prior to Dec. 1, 2015 and which are labeled consistent with the “old” Hazard Communication Standard do not need to be labeled consistent with the GHS requirements.

It is also important to note that the following product categories are exempt from the labeling requirements of HazCom 2012:
    •    Disinfectants, sanitizers, and other pesticide products registered and labeled consistent with EPA regulations.
    •    Hand sanitizers and other over-the-counter drugs labeled consistent with the FDA regulations.
    •    Consumer products that are labeled consistent with the CPSC regulations.