The Consult

The OSHA Hazard Communication (HazCom) Program has been around for over 30 years and ensures that the hazards of all chemicals produced or imported are classified and communicated to employers and employees.

Manufactures and importers are required to evaluate the hazards of chemicals they manufacture or distribute and communicate that information to employers via Safety Data Sheets (SDS) and Labels.

Employers, in turn, must have written programs and training available for their employees that identify hazardous chemicals on site, how information will be shared, and methods employers will use to inform of hazards from chemicals originating from non-routine tasks.

In May, OSHA finalized a rule updating the HazCom Standard. This updated rule takes effect July 19, 2024.

Why the change

In 2012, the hazard communication standard was significantly updated to align with the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS), Revision 3.  Since that 2012 OSHA HazCom update, the UN GHS Standard has been revised multiple times, with the most recent revision being Revision 10, dated 2023.

This recent update finalized by OSHA aligns the HazCom program with a more recent version of GHS, Version 7, dated 2017.

What are the most significant changes

The major changes associated with this update includes:

• Additional definitions added to the standard.
• Requiring labels on small packaging to be more comprehensive and readable.
• Ensuring trade secrets do not prevent workers or first responders from receiving critical hazard information on SDSs.
• Clarifying requirements relative to shipping, aligning with Department of Transportation rules. 

Who must comply

These changes most significantly impact manufacturers and importers, as well as distributors, who evaluate hazards, generate labels and prepare safety data sheets. 

Employers, however, should be aware that as manufacturers and importers are updating their evaluations and information to align with GHS R7, there could be some hazards not previously identified on site that need to be added to your written programs and training.  Also, ensure SDSs are updated and past SDS are archived for 30 years.

For more information, reach out to HRP or see  https://www.osha.gov/hazcom/rulemaking.