The Updated US OSHA Hazard Communication

Life SciencesLife Sciences
July 25, 2024
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Did you know that your SDSs may need to be updated to be compliant with the new regulations?

On May 20, 2024, the U.S. Occupational Safety and Health Administration (OSHA) issued a final rule amending the Hazard Communication Standard (HCS) to align with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS), primarily adopting Revision 7 (Rev 7). This update addresses issues from the 2012 HCS update, improves alignment with U.S. agencies and international partners, and enhances the standard’s effectiveness. The amendments include:

  • Revised classification criteria,
  • Updated label provisions,
  • New small container labeling rules,
  • Trade secret provisions, and
  • Amendments related to safety data sheets (SDS).

The final rule becomes effective on July 19, 2024, with certain provisions retroactively approved as of July 15, 2019. However, the date for chemical manufacturers, importers, and distributors to comply with new SDS and labeling provisions is January 19, 2026, for substances and July 19, 2027, for mixtures. Additionally, employers must update workplace labeling, hazard communication programs, and employee training by July 20, 2026, for substances and January 19, 2028, for mixtures.

Compliance Dates

July 19, 2024 January 19, 2026 July 20, 2026 July 19, 2027 January 19, 2028
Effective date of new OSHA Hazard Communication Standard SDSs and Labels updated for pure substances Workplace information updated for pure substances SDSs and Labels updated for mixtures Workplace information updated for mixtures

 

Key labeling, communication, and training changes include:

  • Adding new hazard classes and categories,
  • Incorporating consensus standards, and
  • Improving hazard communication on labels and SDSs.

Notably, the final rule allows electronic transmission of labels for bulk shipments with the receiving party’s agreement and clarifies requirements for hazard classification and labeling under normal conditions of use.

Appendices A through D of the HCS have also been updated to include new hazard classes like desensitized explosives and revised criteria for health hazards such as respiratory tract corrosion. OSHA’s updates aim to align the HCS with global standards, thereby reducing compliance burdens for U.S. stakeholders who must adhere to international regulations.

The new HazCom final rule is less impactful than the 2012 rule that first aligned HazCom with the GHS, focusing on a few chemical hazard classes and specific details related to chemical classification and SDS information. Many manufacturers will need to reclassify products, resulting in new SDSs and container labels.

SafeBridge offers comprehensive hazard communication and SDS support to meet these regulatory changes for chemical, pharmaceutical, food and beverage ingredient, biotech, oil, gas and refinery and general industry clients across the U.S. Additionally, SafeBridge can provide global compliance analysis or authoring of your SDSs in any of these markets. Please contact Amanda Tuesdale for additional information on our HazCom and SDS services.

I’ve been working with Trinity environmental services for approximately three years, and I can confidently say that they are the best highly respected, skilled professionals in the industry. Trinity has helped me with critical thinking, problem solving and making decisions for complex and ever-changing regulations of hazardous waste management with ease and efficiency.

VP of Regulatory Affairs and Sustainability /Hazardous Waste Company

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