Chemical Hazard Communication Standard Updated in the US

The update to the United States Occupational Safety and Health Administration’s (OSHA) Hazard Communication Standard (HCS) was published on May 20th 2024 and comes into effect on July 19th 2024. The updated standard aligns the HCS with primarily the 7th Revised Edition of the GHS (Rev. 7), and with the recently updated Hazardous Products Regulation (HPR) in Canada.

GHS, the Globally Harmonized System of Classification and Labelling of Chemicals, is an internationally agreed-upon standard managed by the United Nations that was set up to replace the assortment of hazardous material classification and labelling schemes previously used around the world.

Changes to the OSHA hazard classification criteria include: 

• updated health hazard definitions in Appendix A, plus information on the use of non-animal test methods for skin corrosion and irritation to promote the use of these alternative methods. 
• in appendix B, new and updated criteria are included for flammable gases, non-flammable aerosols and desensitised explosives. 
• new provisions for labelling of small containers (3ml and 100ml) as well as updates to label information in Appendix C to align hazard and precautionary statements with Rev. 7.
• safety data sheet updates include the use of prescribed concentration ranges for ingredients where the exact concentrations or concentration ranges are being withheld as a trade secret, aligning with the HPR in Canada, as well as amendments to the SDS format in Appendix D, updating sections 2, 3, 9 and 11 in alignment with Rev. 7.

The updated standard provides an 18-month transition period to January 19th 2026 for substances, and three years  until July 19th 2027 for mixtures.

Employers who handle hazardous chemicals in their workplaces are required to implement comprehensive hazard communication programmes which need to be updated to reflect these changes by July 20th 2026 for substances, and by January 19th 2028 for mixtures. 

Chemical manufacturers, distributors, importers and employers can comply with either the old standard, the new standard, or both during the transition period.

Suppliers should act now to ensure that they can update their safety data sheets (SDS) and other documents to meet the new requirements by the end of the transition periods to avoid potential regulatory enforcement and to meet customer expectations. 

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