New Hazard Communication Standard
OSHA’s Final Rule to Amend the Hazard Communication Standard
U.S. Department of Labor's Occupational Safety and Health Administration (OSHA) has issued a final rule to update the agency’s Hazard Communication Standard (HCS).
OSHA has issued a final rule that updates the Hazard Communication Standard (HCS) to align primarily with the seventh revision of the United Nations’ Globally Harmonized System of Classification and Labelling of Chemicals (GHS). The final rule was published on May 20, 2024 and took effect on July 19, 2024.
The updated standard will improve the standard’s effectiveness by better informing employees about chemical hazards in the workplace. This final rule will increase worker protections and reduce the incidences of chemical-related occupational illnesses and injuries by further improving the information on the labels and safety data sheets for hazardous chemicals. The final rule will also address issues arising since implementation of the 2012 standard and improve alignment with other federal agencies and Canada. Please see the Highlights for more information.
Established in 1983, the HCS provides a standardized approach to communicating workplace hazards associated with exposure to dangerous chemicals. OSHA updated the standard in 2012 to align with the third revision of the GHS. The system provides a common and coherent approach to classifying chemicals and communicating hazard information.
What’s New in HazCom 2023/2024
1. Alignment with GHS Rev. 7 (plus select Rev. 8 elements)
OSHA’s Hazard Communication Standard (29 CFR 1910.1200) now aligns primarily with the 7th revision of the UN’s Globally Harmonized System (GHS), with additional elements from Rev. 8 — such as non-animal testing for skin corrosion/irritation.
2. Enhanced Hazard Classification Criteria
- New/clarified definitions for “bulk shipment” and “combustible dust.”
- Classification must consider intrinsic properties and changes from anticipated uses.
- Clarifications on respiratory corrosion and Specific Target Organ Toxicity (STOT).
3. Updated Labels & Pictograms
- Expanded Appendix C with new hazard classes.
- New flexibility for small package labeling (≤ 100 mL and ≤ 3 mL).
- Bulk shipment labels now better harmonized with DOT requirements.
4. Safety Data Sheet (SDS) Enhancements
- Updated requirements in Sections 2, 3, 9, and 11.
- Allowed use of concentration ranges to protect trade secrets.
Key Dates & Phase-In Schedule
| Date | Required Action | Affected Parties |
|---|---|---|
| May 20, 2024 | Final rule issued | — |
| July 19, 2024 | New standard takes effect; transition period begins | All covered |
| Jan 19, 2026 | Compliance for substances: updated labels & SDS | Manufacturers, importers, distributors |
| July 19, 2026 | Employers update workplace labels, HazCom programs & training | Employers |
| July 19, 2027 | Compliance for mixtures: updated labels & SDS | Manufacturers, importers, distributors |
| Jan 19, 2028 | Employers update labels, HazCom program & training | Employers |
Transition period (May 20, 2024 – respective deadlines): Compliance is allowed with either HCS 2012 or the updated standard.
Impact & Benefits
- Improved clarity: More consistent, readable SDS and labels.
- Worker safety: Better classification and hazard details enhance protection.
- Administrative relief: Labeling flexibility reduces compliance burden.
- Support for innovation: Encourages non-animal test methods and protects trade secrets.
What You Need to Do
For manufacturers, importers, distributors:
- Review and update labels and SDS for substances by Jan 2026 and mixtures by July 2027.
- Ensure hazard classification follows GHS Rev. 7 and applicable Rev. 8 updates.
For employers:
- Update workplace labels, HazCom programs, and training by July 2026 (substances) and Jan 2028 (mixtures).
- Train employees on new SDS format, label features, and hazard classes.
Sources: OSHA, SOCMA, BDLaw, EHSLawInsights, Wikipedia (GHS Revisions)