The Department of Labor has announced a major revision to OSHA’s Hazard Communication Standard. Revealed on Monday, May 20, 2024, this significant update officially came into effect on July 19, 2024. The rollout will be phased, with various compliance deadlines beginning 18 months after the effective date. These important changes to OSHA’s HazCom Rules are designed to enhance worker safety and streamline hazard communication. In this blog, we’ll explore the details of these updates, what they mean for businesses, and how they will lead to a safer workplace environment.

 

The Hazard Communication Standard (HazCom), created by OSHA, aims to ensure that workers are informed about chemical hazards in their workplace. This regulation mandates that employers label chemicals properly, supply safety data sheets, and conduct training to educate employees on potential hazards and safe handling procedures. By providing this critical information, the HazCom Standard seeks to safeguard workers and promote a safer work environment when dealing with hazardous substances.

 

OSHA’s new updated rules have been designed to increase and enhance the overall effectiveness of the hazard communication standard. The revised version will now provide more useful information regarding chemical safety. Above all, it is expected that the revised standards will help strengthen worker protection. It will be helpful to reduce chemical-related incidents and accidents even more. Also, most of the issues identified since the implementation of the previous standard will be addressed. 

 

What exactly are these newly revised HazCom standards? Continue reading to know more about it. 

 

OSHA’s New HazCom Rules:

 

The newly revised HazCom standard has observed some major changes. In the latest rule, OSHA has introduced changes in the following areas:

 

  • Revised hazard classes and classification criteria.
  • Changes in labeling allowances. The requirements for “small” and “very small” containers have also changed.
  • Labeling provisions for containers have been updated.
  • Revised criteria for classifying chemicals
  • New information requirements for Safety Data Sheets (SDSs)
  • Expanded and updated methods and instructions for classifying certain chemicals

 

But what are the changes that are going to be observed in such areas? Below we have mentioned all the changes in detail, so take a quick look. 

 

  • Hazard Classes and Classification Criteria: 

 

The Updated hazard classifications now include revised categories for aerosols, desensitized explosives, and flammable gases. It also includes a new category for chemicals under pressure within the aerosols class.

 

  • Labelling Allowance

 

Chemical manufacturers must use abbreviated shipped container label information on containers with 100 ml or fewer chemicals. For a 3 ml smaller container only a product identifier would be enough. The outer packing containers must have full shipped information details.

 

  • Labels for Containers Rereleased for Shipment: 

 

Manufacturers, importers, or distributors who learn of new significant hazard information do not need to relabel chemical products that have already been shipped or are ready for shipment (bundled, palletized, etc.).

 

  • Classifying a Chemical:

 

Chemical manufacturers must now consider the intrinsic properties and potential hazards of their products. It also includes those expected from downstream uses when classifying them. These details must be included in Section 2 of the Safety Data Sheets (SDS).

 

  • Information Requirement for SDSs:

 

There are several updates to the information required on Safety Data Sheets (SDSs). These include adding “particle characteristics” to Section 9, ensuring Section 1 contains domestic contact information, and providing updated instructions for chemical manufacturers on what to include in Section 2.

 

  • Expanded Classification Method:

 

New classification methods are now allowed for certain chemicals. It includes oxidizing solids also along with several other categories that have been updated or clarified.

 

Why was the HAZCOM Standard Revised in 2024?

 

OSHA continually updates its standards to ensure maximum worker safety. In 2012, OSHA aligned its Hazard Communication Standard with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The GHS provides criteria for classifying health, physical, and environmental hazards. It shares detailed information on hazardous chemical labels and SDSs.  

 

The GHS is updated with new improvements and clarifications and it happens every two years. Consequently, OSHA must regularly update its standards to stay aligned with the GHS and keep pace with evolving technology. In 2017, GHS adopted revision 7, prompting OSHA to revise its standards and publish new rules to maintain this alignment.

 

With these newly updated rules, OSHA has tried to address some major factors. Stakeholders faced issues related to the labeling of small containers and the labeling of chemicals released for shipment. The new standard has addressed these issues and has some useful instructions.  Besides, the new standard is revised to align with other US agencies

 

What are the Changes in OSHA’s Hazard Communication Standard?

 

To know all the changes in the HCS 2024, check out the points below. They will help you gain a better understanding. 

 

Newly Updated Classification Criteria:

 

Hazardous products will be classified in new criteria from now on. Here’s what you need to know: 

 

  • Flammable Gases: 

OSHA has subdivided the previous Category 1 into Category 1A and 1B. Pyrophoric gases and chemically unstable gases are now classified as Category 1A. Thus it offers more precise hazard information and aligns with GHS Rev. 7.

 

  • Desensitized Explosives: 

A new hazard class for desensitized explosives has been added. It includes four categories (1, 2, 3, and 4). Desensitized explosives are chemicals that have been treated to make them less likely to explode. To qualify as a desensitized explosive, the chemical must be solid or liquid, must stay mixed with its stabilizing agent, and cannot also be classified as an explosive, flammable liquid, or flammable solid.

 

  • Aerosols: 

The existing Flammable Aerosols hazard class has been renamed to “Aerosols”. It is expanded to include non-flammable aerosols under a new Category 3. Flammable aerosols remain in Categories 1 or 2. It mainly reflects a broader range of aerosol hazards.

 

  • Chemicals Under Pressure: 

A new category within the aerosols class, “Chemicals Under Pressure,” includes three distinct categories based on pressure levels and hazard characteristics. This category addresses liquids or solids pressurized in non-aerosol containers.

 

Classification by Chemical Properties:

 

OSHA’s revised rules mandate that hazard classifications must account for the chemical’s intrinsic properties including changes in physical form and reaction products from known or reasonably anticipated uses.

 

  • Section 2 of the SDS

Hazards from chemical reactions must be detailed in Section 2(c) of the Safety Data Sheet (SDS). Besides,  hazards due to changes in intrinsic and physical form should be listed in Section 2(a).

 

  • Public Concerns Addressed

Feedback from stakeholders revealed concerns about the feasibility of classifying chemicals based on all possible uses and scenarios. OSHA’s final rule narrows the expectations to only “known or reasonably anticipated uses.

 

  • Feasibility and Scope

OSHA understands that it’s not practical for manufacturers to consider every possible use of a chemical. Instead, they only need to make a reasonable effort to classify chemicals based on what they know about their uses.

 

  • Manufacturer’s Responsibility

Manufacturers, importers, and distributors are not expected to perform exhaustive investigations. They only need to provide sufficient information about hazards based on their knowledge or what can reasonably be known.

 

Rules for Small Containers:

 

Containers with a volume of 100 mL or less are classified as small containers. The new standard has some provisions for it. 

 

  • Labeling Requirements: Manufacturers, importers, and distributors may use abbreviated label information on small containers if full labeling is impractical due to size constraints. They must demonstrate that it’s not feasible to use pull-out labels, fold-back labels, or tags to include the full label information.

 

  • Very Small Containers: For containers of 3 mL or less, only the product identifier is required on the immediate container if a full label obstructs its use. However, the full shipped container label must be provided on the outer packaging.

 

Rules for Small Containers

 

 

Rules for Containers Released for Shipment:

 

OSHA has eliminated the requirement for chemical manufacturers to relabel packages that have already been released for shipment. This change addresses safety concerns related to accessing and relabeling containers that are difficult to reach.

 

Previously, relabeling palletized or bound containers could lead to employee injuries or chemical spills. The new rule removes the need to relabel such containers, addressing stakeholder concerns about the difficulties and risks involved. Additionally, the requirement for including a “released for shipment” date on labels has been dropped due to feedback about space limitations, costs, and practical challenges.

 

 

Impacts of the Revised HazCom Standards

 

The change in the HCS is going to impact multiple industries as they need to stay updated with the new rules, understand them, and stay compliant. Key changes include:

  • Learning the Updates: All employers must understand the new rules.
  • Training Safety Staff: Health and safety specialists need to be trained on the updates.
  • Employee Training: Employers must train employees on the new standards

Manufacturers and suppliers now need to do some extra work. They need to update the classification for aerosols, desensitized explosives, and flammable gases. Besides, they must revise safety data sheets and labels to match the new criteria.

Compliance Deadlines

What are the Compliance Deadlines?

 

The HazCom Standard revisions will take effect 60 days after being published in the Federal Register, on July 19, 2024.

 

Compliance for Substances:

  • Deadline: January 19, 2026

Compliance for Mixtures:

  • Deadline: July 19, 2027

Alternative Workplace Labeling and Hazard Communication Program:

  • Deadline for Substances: July 19, 2026
  • Deadline for Mixtures: January 19, 2028

 

Conclusion:

The new standard is more informative and includes clarifications missing in the earlier version. Its goal is to enhance workplace safety by providing more comprehensive hazard information. Organizations need to understand and follow the new rules to ensure compliance and effectively communicate hazards.