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2024 Updates to the OSHA HazCom Standard: What you should Know!

The Department of Labor announced this week the publication of the final rule of the Occupational Safety and Health Administration’s (OSHA) Hazard Communication (HazCom) Standard. The updates take effect on July 19, 2024. 

The updated standard is aligned with the seventh revision of the United Nations’ Globally Harmonized System of Classification and Labelling of Chemicals (GHS). In addition, some portions of the eighth revision of GHS are included. OSHA’s last update to the HazCom Standard was published in 2012 and incorporated the third revision of GHS.

The May 20, 2024 final rule includes the addition of one new hazard class (desensitized explosives). New hazard categories were also added including chemicals under pressure within the aerosols class and unstable gases in the flammable gases class.

In addition, new definitions were added including those for bulk shipment, combustible dust, gas, liquid, solid, immediate outer package, physician or other licensed health care professional (PLHCP), and released for shipment.

The final rule also includes updates to:

  • Requirements for conducting a hazard classification which involve addressing hazards associated with the chemical’s intrinsic properties including a change in the physical form and chemical reaction products associated with known or reasonably anticipated uses or applications.
  • For chemicals that have been released for shipment and are awaiting future distribution, manufacturers, importers, and distributors that become aware of new significant hazard information have the option not to relabel those containers; however, if they do not relabel the containers, they must provide the updated label for each individual container with each shipment.
  • New labeling provisions for small containers (100 mL or less) that allow chemical manufacturers, importers, or distributers to use an abbreviated version of shipped container label information and very small containers (3 mL or less) which in some cases will only require a product identifier.
  • Increasing coordination between OSHA and the Department of Transportation (DOT) regarding labeling regulations on bulk shipments including updates to the language to indicate that when a DOT label is on the container then the OSHA pictogram for the same hazard is not required.  
  • Provisions related to Safety Data Sheet (SDS) information on trade secrets to help ensure they don’t prevent workers and first responders from receiving hazard information. Manufacturers are now required to disclose the concentration range based on a prescribed list of range options, and the narrowest range has to be included on the SDS.
  • Content of Safety Data Sheets including the addition of information on chemical reaction products associated with known or reasonably anticipated uses or applications in Section 2, the addition of particle characteristics for solid products in Section 9, and in Section 10, clarifying that hazards associated with foreseeable emergencies should be included.
  • Pictograms now include the addition of desensitized explosives in the flame pictogram and hazards not otherwise classified (HNOC) have been added to the exclamation point pictogram.
  • Some precautionary statements (included in Appendix C) on how to safely handle, store, and dispose of hazardous chemicals have been updated. This will affect the content of some labels and SDS.
  • Appendix A, Health Hazard Criteria includes revised health hazard definitions and revisions to the sections on skin corrosion/irritation and serious eye damage/irritation, with non-animal test methods added to skin corrosion/irritation to promote the use of alternative test methods. Although some changes were made to the health hazard criteria, the classification of existing chemicals is expected to remain unchanged.
  • Appendix B, Physical Hazard Criteria includes expanding the flammable gases and aerosols hazard categories. The updates to several physical hazard classes are expected to result in changes in the classification of physical hazards for some previously classified chemicals.

Because the final rule will require manufacturers to reclassify the physical, health, and other hazards of some of their chemicals, there will be a need to provide downstream users/employers with updated SDSs. In addition, in some cases, chemicals will require updated labels. Users of these chemicals will need to ensure that they are maintaining updated SDSs and are incorporating updated hazard classifications in their workplace labels. The written Hazard Communication Program and HazCom training may also need to be updated.

Chemical manufacturers, importers, and distributors have until January 19, 2026 (for chemical substances) to July 19, 2027 (for mixtures) to comply with the new rule.

Employers have an additional six months (July 20, 2026 for substances and January 19, 2028 for mixtures) to come into compliance.

For additional information on the Hazard Communication Standard final rule and how the changes might affect your organization, please contact us.

This blog was written by Beth Graham, Safety Partners’ Director of Quality, Research, and Training.

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