The Occupational Safety and Health Administration (OSHA) has issued a final rule that updates the Hazard Communication Standard (HCS) to align primarily with the 7th revision of the United Nations’ Globally Harmonized System (GHS) for the classification and labelling of chemicals. The final rule took effect on July 19, 2024, with changes impacting chemical manufacturers, importers, distributors, and companies that use hazardous chemicals. The rule is being phased in over a 4-year period as shown in the timeline below (Fig. 1).
The rule changes improve alignment with other federal agencies like the Department of Transportation (DOT) and Health Canada’s Workplace Hazardous Materials Information System (WHMIS).
Updates and Revisions
The final HCS includes changes to definitions and appendices, among others. These changes affect the criteria for classification, label elements, and handling of hazardous chemicals.
Revisions include:
1. Definitions – additions or clarifications to the following terms:
- Additions: Bulk shipment, Combustible dust, Gas, Immediate outer package, Liquid, Physician or other licensed health-care professional (PLHCP), Released for shipment, Solid
- Clarifications: Exposure or Exposed, Pyrophoric gas
2. Addition of Section (f)(5) Transportation clarifying labeling for bulk shipments and pictograms to align with the DOT. Eliminates the need for both DOT and HCS pictograms for the same hazard.
3. Special labelling provisions for 3 ml and 100 ml containers.
- For containers ≤100 ml, the label must contain, at a minimum, the product identifier, pictogram(s), signal word, Chemical manufacturer’s nae and phone number, and a statement that the full label information is provided on the immediate outer package.
- For containers ≤3 ml capacity, where the chemical manufacturer, importer, or distributor can demonstrate that any label interferes with the normal use of the container, no label is required, but the container must bear, at a minimum, the product identifier.
- The full label information required by this section of the standard must be included on the immediate outer package. The label must not be removed or defaced, and must include a statement that the small container(s) inside must be stored in the immediate outer package bearing the complete label when not in use.
4. Trade secrets – Mandatory use of prescribed concentration ranges when exact percentages or percentage ranges of materials are claimed as a trade secret.
5. Appendices A – D have been revised to align with DOT and GHS test methods, update the classification of aerosols and gases under pressure, and prescribe minor changes to label and Safety Data Sheet (SDS) elements.
Employers Should Take the Following Actions
To comply with the recent HCS updates, employers should take the following actions:
Review and Understand the Changes:
- Familiarize yourself with the updated HCS, which now aligns with the 7th edition of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). This alignment provides a consistent approach to classifying chemicals and communicating hazard information on labels and SDS.
- Understand the specific changes related to hazard classification, labels, and SDSs.
- You can find a side-by-side comparison of the current vs. revised standard here.
Update Labels and SDSs:
- Chemical manufacturers and importers must update label elements, especially for small chemical containers. Assure your in-house labels incorporate those changes, too.
- When new manufacturer’s labels and SDSs arrive at your facility, assure they are readily available for exposed workers.
- Safety Data Sheets (SDSs) will now contain more detailed information on Trade Secrets.
Train Workers:
- Employers with hazardous chemicals in their workplaces must train workers on the new label elements and SDS format to enhance hazard recognition and understanding.
Remember that compliance with either the 2012 version or the 2024 version of the HCS is acceptable for periods prior to those dates. If you have any specific questions or need further guidance, contact us….etc.
Milestone Dates to Remember
The updated standard allows for a transition period with four milestones for compliance.
If you have any specific questions or need further guidance on how to adhere to updated Hazard Communication Standard, contact Cardinal Compliance Consultants.