This week (November 2015) I have been working with a small employer who is not staffed with a full time EHS professional Great folks, but like many small employers we have a ways to go to get where we need to be. So we started with what I believe to be a bedrock of any safety program… HAZCOM. As we know this standard has been turned upside these last couple of years and we have passed some significant milestones in this transition this year. As I was digging through their MSDS binders to see how they are faring on that front I was SHOCKED at what I was seeing. Since I am no longer a safety manager at a facility I guess I have been “assuming” too much in how things are progressing in our transition to the new GHS, specifically to the NEW SDS format and content. It seems there are some manufacturer’s and importers that appear to have dropped the ball in a big way when it comes to UPDATING their MSDS to comply with the new SDS requirements! This week I talked with over a dozen companies who proceeded to tell me that their “MSDS” was fully compliant with the new SDS requirements and that they would not be issuing any revisions for the MSDS. They could not be any more WRONG and I am guessing it will not sink in until hundreds of other EHS professionals begin to rattle their cage(s). So what MUST be on an MSDS as of June 1, 2015 that most likely is NOT on an MSDS that developed before the GHS…