New Hazard Communication Requirements Effective July 19

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 was published on May 20, 2024, and takes effect on July 19, 2024, with changes impacting chemical manufacturers, importers, distributors and companies that use hazardous chemicals.

The updated standard allows for a transition period with four milestones for compliance. The rule has improved 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:

• Definitions – additions or clarifications to:
  • Bulk shipment – (addition)
  • Combustible dust – (addition)
  • Gas – (addition)
  • Immediate outer package – (addition)
  • Liquid – (addition)
  • Physician or other licensed health-care professional (PLHCP) – (addition)
  • Pyrophoric gas – (clarification)
  • Released for shipment – (addition)
  • Solid – (addition)
• Addition of Section (f)(5) Transportation clarifying labeling for bulk shipments and pictograms to align with the DOT.
• Special labelling provisions for 3 ml and 100 ml containers.
• Trade secrets – Mandatory use of prescribed concentration ranges when exact percentages or percentage ranges of materials are claimed as a trade secret.
• Appendices A – D
  • A2 – Skin Corrosion/Irritation – Revisions to align with DOT, GHS, and with non-animal test methods.
  • A3 – Serious Eye Damage/Eye Irritation – Revisions to GHS tiered approach and animal test data use.
  • B3 is now Flammable Aerosols and Chemicals Under Pressure – Flammable gases (expanding hazard categories), and Aerosols (including additional hazard category).
  • B17 – Addition of Desensitized Explosives
  • C – Label Elements – Changes carried over from changes in Appendix A and B.
  • D – Minor changes to 16 sections of safety data sheets (SDSs)

Transition Dates for Compliance

OSHA has outlined a tiered approach for compliance that provides adequate time to transition these new regulatory requirements into company operations as needed, with deadlines beginning 18 months from now.

Next Steps: TRC Can Help

It is important for impacted organizations to review these new hazardous chemical communications requirements and begin implementing process and plans to maintain compliance. TRC’s safety compliance professional scan support the HCS transition by updating your current program, revising training materials, instituting SDS updates, and/or providing guidance on the implementation of applicable changes. For more information on TRC’s safety compliance services, please contact us today.