OSHA Updates the Hazard Communication Standard (HCS) 2024

OSHA Updates the Hazard Communication Standard (HCS) 2024

The U.S. Occupational Safety and Health Administration (OSHA) has issued a final rule to amend the Hazard Communication Standard (HCS). This update aims to align the HCS with the 7th edition of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS), while also including elements from the 8th revision, ensuring clear communication about the risks of chemical substances in the workplace.

The changes include updated classification criteria, uniform labeling, and worker training on chemical hazards.

Reasons for Updating the Hazard Communication Standard

The key motivations for updating the Hazard Communication Standard include:

  • •The need to align the HCS with the seventh revision of the GHS to ensure effective global communication.
  • •Promoting uniformity in chemical hazard communication to enhance worker safety and protection.
  • •Updating the classification and labeling criteria of chemical substances to reflect advancements in hazard identification.

Key Changes in the HCS Update

The modification of the Hazard Communication Standard involves adopting new criteria for hazard classification, summarized below.

New Categories of Physical Hazards:

  • •Desensitized Explosives: The classification of desensitized explosives has been updated to align with GHS 8th revision.
  • •Flammable Gases:
  • Pyrophoric gases and chemically unstable gases are now included in Flammable Gases Hazard Class 1A, with two subcategories: Chemically Unstable Gases A and Chemically Unstable Gases B.
  • A new class, Flammable Gases 1B, has been added.
  • •Aerosols: A new category has been added, resulting in three classes based on combustion properties and the percentage of flammable components.
  • •Chemicals Under Pressure: Three new categories have been added to align with GHS 8th revision.

New Health Hazards:

The definition of Germ Cell Mutagenicity has been revised.

Supplementary information has been added for the categories: Acute Toxicity, Skin Corrosion/Irritation, Serious Eye Damage/Eye Irritation, and Specific Target Organ Toxicity (Single Exposure).

Human experience data can now be included in acute toxicity assessments.

Labeling:

Regarding label revision, manufacturers, importers, and distributors are allowed not to relabel chemicals released for shipment and pending distribution, provided they supply the updated label with each shipment or to the receiving entity.

Updated Labeling for Small Containers:

  • • Very Small Container Capacity ≤ 3ml: No label is required, but the container must have at least the product identifier and special labeling on the immediate outer package indicating that the small container should be stored in the immediate outer package with the full label when not in use.
  • • Small Container Capacity ≤ 100ml: Must include (A) Product Identifier; (B) Pictogram(s); (C) Signal Word; (D) Manufacturer's name and phone number; and (E) A statement that the full chemical hazard label information is provided on the immediate outer package.

Changes to Safety Data Sheets:

  • •Section 2: To align with these changes in paragraph (d)(1), in Section 2 (a), OSHA replaces its original proposed language with "in accordance with paragraph (d)(1)(i) of § 1910.1200”.
  • The classification of the mixture must additionally consider the hazards associated with potential physical state changes or chemical reactions that may occur during use.
  • •Section 3: Concentration ranges are established for substances declared as trade secrets.
  • •Section 9: A field for particle characteristics for solid-state products is added.
  • •Section 11: When specific chemical information or data is unavailable, the preparer must indicate if alternative information is used, and the method employed to obtain the information.

The regulation comes into effect on July 19, 2024, with compliance required for substances by January 19, 2026, and for mixtures by July 19, 2027.

Our Chemeter software includes these updates, allowing the creation of SDS for the U.S. according to the new regulation, ensuring compliance with the latest legislative requirements of each country/region and enabling users to stay worry-free.