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 (EHS) 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 one hundred eight 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 54 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 OSHA 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 the target date for compliance with the new GHS format. They were required 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 due date and introduced “good faith” efforts companies could make to avoid penalties. These efforts included documenting the “reasonable diligence” efforts made to obtain the information necessary to meet GHS compliance and providing 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 some companies missing the GHS deadline 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 and finding a sufficient GHS labeling solution/provider tying for third (13 percent).

Investing in the GHS

According to the United States Department of Labor, OSHA’s HCS alignment with the GHS is expected to affect more than 40 million workers in over 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 systems 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 OSHA’s June 1, 2016 deadline.

As outlined in the survey, the majority of these investments were earmarked for EHS 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 EHS management software that helps secure, track, and maintain SDSs was the single biggest investment made by companies looking to comply with the GHS.

The 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 effect on business, regulatory compliance is and continues to be a top concern for EHS 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, forcing 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 towards achieving GHS compliance long after OSHA’s final GHS deadline.