OSHA has been involved with a long-term project to be aligned with the Globally Harmonized System (GHS) of classifying chemical hazards and providing labels and safety data sheets for hazardous chemicals. OSHA incorporated the GHS system into the Hazard Communication Standard (HCS) in March 2012 to specify requirements for hazard classification and to standardize label components and information on safety data sheets, in an effort to enhance both employer and worker comprehension of hazards and facilitate international compliance.

The GHS has been updated several times since OSHA’s 2012 rulemaking which was based on the third edition of the GHS and the United Nations recently completed the seventh edition. OSHA is now in the process of conducting rulemaking to harmonize the Hazard Communication Standard (HCS) to the latest edition of the GHS and to codify a number of enforcement policies that have been issued since the 2012 standard. OSHA has recently published a new Proposed Rule “Update to the Hazard Communication Standard.” The associated Notice of Proposed Rulemaking was expected be published in March 2019, but it has been delayed. Final rulemaking is now not expected until 2020.

OSHA plans to update its Hazard Communication Standard to conform with the latest 2017 edition of the GHS. OSHA’s HCS may also be updated to conform with the earlier editions of the GHS. An overriding principle of the GHS is that nations and agencies have the flexibility to pick and choose which elements of the GHS to adopt. This means OSHA does not have to adopt all of Revision 7, but instead can select changes that work within the scope of its regulatory oversight for hazardous chemicals in the US. That said, expected changes with the alignment to Revision 7 include:

  • Modified criteria for the categorization of flammable gases.
  • Updated health and physical hazard class definitions and categories.
  • Revised precautionary statements.
  • Additional information to be included in Section 9 of Safety Data Sheets (SDSs).

We’ll continue to track these planned updates to the Hazard Communication Standard and will update you as more information becomes available. If you have any questions on the proposed changes or how they will affect your company, please email info@safetypartnersinc.com.

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