The Department of Labor’s Occupational Safety and Health Administration (OSHA) recently issued a final rule updating its Hazard Communication Standard (HCS). The revised standard, which aligns primarily with the seventh revision of the United Nations’ Globally Harmonized System of Classification and Labelling of Chemicals (GHS), will more effectively inform workers about chemical hazards in the workplace and thus reduce the number of chemical-related illness and injuries, according to OSHA. The final rule, which was published May 20, 2024, takes effect July 19, 2024.
The HCS
The HCS was established in 1983 to provide a standardized approach to communicating workplace hazards associated with exposure to dangerous chemicals. The standard requires chemical manufacturers and importers to classify the hazards of chemicals they produce or import, and to prepare labels and safety data sheets to convey the hazard information to their downstream customers. It also requires that all employers with hazardous chemicals in their workplaces inform employees through a hazard communication program, labels and other forms of warning, safety data sheets, and training on how to handle chemicals safely. The HCS was previously updated in 2012.
What’s Changing?
The scope and basic structure of the HCS remain the same, but with various amendments designed to enhance its effectiveness. Modifications include revised criteria for classifying certain health and physical hazards, in order to better capture and communicate the hazards to downstream users. There are also revised provisions for labels, which include addressing the labeling of small containers and the relabeling of chemicals that have been released for shipment. There are also revised definitions, amendments pertaining to the contents of safety data sheets, and specification of concentration ranges allowed to preserve trade secrets.
Compliance Deadlines
OSHA announced deadlines for compliance with various aspects of the final rule. Chemical manufacturers, importers, distributors, and employers must provide updated labels and safety data sheets for substances within 18 months of the effective date (January 19, 2026), and for mixtures within 36 months of the effective date (July 19, 2027). Employers must make updates to their hazard communication program and any alternative workplace labeling and provide additional employee training as necessary within 24 months of the effectiveness date (July 20, 2026) for substances and within 42 months (January 19, 2028) for mixtures.
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