OSHA 1910.1200: Hazard Communication Standard

“Updating your SDS and training is crucial to comply with OSHA’s 2024 HCS update. For CHEMTREC, helping customers with these changes is paramount for maintaining our reputation as a leader in chemical emergency response and information management. Adhering to the latest standards is essential for the safety of workers and the public. This commitment to compliance and safety is at the core of our mission and reinforces the trust that our stakeholders place in us,” said Heather Walker, Associate Director of Product Development and Implementation at CHEMTREC: 1-800-262-8200, www.chemtrec.com

OSHA’s Hazard Communication Standard (HCS) requires chemical manufacturers or importers to classify the hazards of chemicals they produce or import. It also requires all employers to provide information to their employees about the hazardous chemicals to which they are exposed, by means of a hazard communication program, labels and other forms of warning, safety data sheets (SDSs), and information and training.

Established in 1983, the HCS provides a standardized approach to communicating workplace hazards associated with exposure to dangerous chemicals. OSHA updated the standard in 2012 to align with the third revision of the United Nations’ Globally Harmonized System of Classification and Labelling of Chemicals (GHS). The system provides a common and coherent approach to classifying chemicals and communicating hazard information.

The agency published a final rule updating the HCS to align primarily with the seventh revision of the GHS on May 20, 2024. It took effect on July 19, 2024.

The updated standard is intended to improve the standard’s effectiveness by better informing employees about chemical hazards in the workplace. This final rule will increase worker protections and reduce the incidences of chemical-related occupational illnesses and injuries by further improving the information on the labels and safety data sheets for hazardous chemicals. The final rule will also address issues arising since implementation of the 2012 standard and improve alignment with other federal agencies and Canada.

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Why an Update?

Most of the key changes in this update were made to maintain alignment with the GHS and U.S. trading partners; address issues identified during implementation of the 2012 update to the HCS; and improve alignment/coordination with other U.S. agencies, such as the U.S. Department of Transportation (DOT) and the U.S. Environmental Protection Agency (EPA). They are intended to improve dissemination of information about chemical hazards by:

• Improving and streamlining precautionary statements
• Providing additional clarification of existing regulatory requirements
• Incorporating new hazard classes and categories
• Increasing alignment with other U.S. agencies and international trading partners.

Training Workers on the Updated HCS

The GHS recognizes that training is essential to an effective hazard communication approach. The revised HCS requires that workers be re-trained within two years of the publication of the final rule to facilitate recognition and understanding of the new labels and Safety Data Sheets (SDS). The updated HCS has introduced specific changes in labeling, SDS, and classification criteria designed to significantly reduce the risk of injuries and illnesses related to chemical exposure. Understanding these changes is essential for compliance and to avoid penalties. Employees need to learn to recognize and respond to chemical hazards in the workplace.

Training on the updated HCS should include:

Labeling Requirements: Understanding the new standardized label elements, including pictograms, signal words, hazard statements, precautionary statements and product identifiers to help employees quickly and accurately identify the nature and severity of chemical hazards.

Safety Data Sheets (SDS): The 16-section format of the SDS provides critical information about chemical properties, health hazards, protective measures and safety precautions. Learning how to read and interpret these sheets is vital to understanding proper handling and emergency response.

Chemical Classification: Workers involved in handling, storing and disposing of hazardous substances must understand the updated criteria for classifying chemicals according to their health and physical hazards.

Which Establishments are Covered by the Update to the HCS?

The scope and framework of the HCS have not changed with this rulemaking. Chemical manufacturers and importers are still responsible for providing information about the hazards of chemicals they produce or import. All employers with hazardous chemicals in their workplaces continue to be required to have a hazard communication program and to provide information to employees about these hazards and associated protective measures.

The Numbers

Citations regarding this standard by Federal OSHA for inspections during the period October 2023 through September 2024:

Anticipated Benefits of the Update

OSHA believes this update to the HCS will improve worker protections by clarifying existing regulatory requirements, incorporating new hazard classes and categories, and improving and streamlining precautionary statements. In addition, updates that increase alignment with key trading partners will facilitate international trade.

OSHA estimates that the final rule will affect 111,223 firms, 147,832 establishments, and 1,530,476 employees and, for each affected industry, will either provide cost savings or the costs would be less than 1 percent of revenues or 10 percent of profits. The net cost savings of the final rule are expected to be $29.8 million per year.

Additional Resources

OSHA has developed a redline strikeout version of the regulatory text and appendices to help workers, employers, and other stakeholders understand the changes to the HCS. It can be found on the OSHA Hazard Communication safety and health topics page: www.osha.gov/hazcom. wmhs