Preparing for OSHA’s Hazard Communication Standard Update

In February, the U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) proposed a rule update to its Hazard Communication Standard (HCS), aligning it with the seventh revision of the Globally Harmonized System of Classification and Labelling of Chemicals (GHS). First finalized in 1983, the HCS standardized workplace hazard communications associated with exposure to hazardous chemicals. It was last updated in 2012 with a common and coherent means of classifying chemicals and communicating hazard information. While OSHA accepted public comment through May 19, 2021, and has yet to finalize the update, we are encouraging our staff and clients to familiarize themselves with the proposed changes.

Impacts to Employers

While it is not expected to change the fundamental structure of the HCS, the regulatory update will require revisions to written HCS and training for staff who are exposed to hazardous chemicals during work.

Staff should be trained to understand new requirements on Safety Data Sheets (SDSs), as well as new hazard statements and labeling small chemicals. Since chemical manufacturers and importers will be required to provide English SDSs and new labeling, staff receiving and handling these chemicals should be prepared for the label update and safety guidelines for handling the chemicals to avoid exposures. Due to lengthy storage and distribution periods, this revision allows new labels to be sent with chemical shipments or electronically in advance.

The update also changes the labeling requirement for small chemical containers. Containers with a capacity between 3 ml and 100 ml at minimum would require a label identifying the product with pictogram(s), signal word, chemical manufacturer’s name and phone number, and a statement that the full label information is provided on the immediate outer package. Containers with a capacity equal to or less than 3 ml in which a label would hinder normal use would only require a product identifier and a statement that the small container(s) inside must be stored in the immediate outer package containing the full label information when not in use.

Changes in definitions and classification of hazards

The update includes changes to the definitions of “exposure or exposed,” “hazardous chemicals,” and “physical hazard,” which will also revise the criteria for classifying health and physical hazards in Appendices A and B. This includes:

  • revised health hazard definitions
  • extensive revisions to the sections on skin corrosion/irritation and serious eye damage/irritation
  • changes to the flammable gases hazard class
  • expansion of the flammable aerosol hazard class to also include non-flammable aerosols
  • adding a new physical hazard class for desensitized explosives

Eight terms will also be added to the HCS with definitions for “bulk shipment,” “combustible dust,” “gas,” “liquid,” “solid,” “immediate outer package,” “Physician or other licensed health care professional (PLHCP),” and “released-for-shipment.” These revised and additional definitions will also require those who handle hazardous chemicals to understand the implication of new terms.

Preparing for compliance

We do not yet know when these updates will go into effect or if changes may be made to the rule as currently proposed. However, Woodard & Curran can help companies review Hazard Communication Programs for regulatory compliance with the existing and forthcoming updates, as well as assess effectiveness. Our experts can also assist clients who need to establish a Hazard Communication Program under the new rule with an inventory of chemicals, collection of SDSs, and development of employee training in multiple formats.


Mary House Director of Practices Environment

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