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Overview of Changes

The Occupational Safety and Health Administration (OSHA) finally released its changes to the Hazard Communication Standard (HCS). OSHA’s intended purpose for these regulatory revisions is to bring the United States into alignment with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). While OSHA’s Hazard Communication Standard, first promulgated in 1983, gave the workers the ‘right to know,' the Agency publicizes that the new Globally Harmonized System gives workers the ‘right to understand.’

The new hazard communication standard still requires chemical manufacturers and importers to evaluate the chemicals they produce or import, and provide hazard information to employers and workers by putting labels on containers and preparing safety data sheets (SDS), previously called Material Safety Data Sheets. However, the old standard allowed chemical manufacturers and importers to convey hazard information on labels and material safety data sheets in whatever format they chose. The modified standard provides a single set of harmonized criteria for classifying chemicals according to their health and physical hazards, and specifies hazard communication elements for labeling and safety data sheets.

The following is a brief outline of the major changes to the Hazard Communication Standard. Further details on select topics can be found in SGIA’s HCS Fact Sheets.

  • Hazard classification: Chemical manufacturers and importers are required to determine the hazards of the chemicals they produce or import. Hazard classification under the new, updated standard provides specific criteria to address health and physical hazards, as well as classification of chemical mixtures.
  • Labels: Chemical manufacturers and importers must provide a label that includes a signal word, pictogram, hazard statement, and precautionary statement for each hazard class and category.
  • Safety Data Sheets: The new format requires 16 specific sections, ensuring consistency in presentation of important protection information.
  • Information and training: To facilitate understanding of the system, the new standard requires that workers be trained by December 1, 2013 on the new label elements and safety data sheet format, in addition to current training requirements.

Various provisions of the new standard have different effective dates. Employers should continue to update their safety data sheets as new ones become available, provide training on the new label elements, and update hazard communication programs if new hazards are identified.

Companies producing safety data sheets need to review hazard information for all chemicals produced or imported, classify chemicals according to the new classification criteria, and update labels and safety data sheets according to the new specified format.

HCS Resources
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New Labeling Requirements under Revised Hazard Communication Standard

New Safety Data Sheet Requirements
Changes That Impact Employers
Effective Completion Date Requirement(s) Who
December 1, 2013 Train employees on the new label elements and SDS format. Employers

June 1, 2015*
(This date coincides with the European Union implementation date for classification of mixtures.)

Comply with all modified provisions of this final rule, except:

Distributors may ship products labeled by manufacturers under the old system until December 1, 2015.
Chemical manufacturers, importers, distributors and employers
June 1, 2016 Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards. Employers
Transition Period Comply with 29 CFR 1910.1200 (this final standard), the current standard, or both. All chemical manufacturers, importers, distributors and employers

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