As you manage your chemical inventory and safety data sheet (SDS) library, staying updated on regulatory changes is crucial. The Occupational Safety and Health Administration (OSHA) has issued a new final rule that aligns the Hazard Communication Standard (HazCom) with Revision 7 (and elements of Revision 8) of the United Nations’ Globally Harmonized System for Classification and Labelling of Chemicals (GHS). Here’s what you need to know.

Main Changes in OSHA’s HazCom Final Rule

1. Revised Classification Criteria

The final rule introduces updated classification criteria for specific chemical products, including aerosols, desensitized explosives, and flammable gases. A new hazard category, "Chemicals Under Pressure," has been added, following GHS Revision 8. These changes will impact hazard pictograms and precautionary statements.

2. Updated Label Provisions

o Small Containers: The rule incorporates previous guidance on labeling small containers (100 mL or less) directly into the Standard. Manufacturers can use abbreviated label information for these containers.
o For very small containers (3 mL or less), only the product identifier is required if full labeling interferes with usage. However, complete label information must appear on outer packaging.
o There’s no need to relabel products already shipped when new hazard information arises, and OSHA has removed the proposed requirement for a “released for shipment” date on labels.

3. Classification Amendments

The final rule clarifies responsibilities for hazard classification, stating that it must include hazards from a chemical’s intrinsic properties, including:

o Changes in physical form
o Chemical reaction products associated with known uses

This delineation affects information in Section 2 of the SDS, clarifying where specific hazards should be listed.

4. Additional Information Requirements

The final rule requires the addition of “particle characteristics” for solid products in Section 9 of the SDS, but only if that information is readily available. Manufacturers are not required to conduct tests to obtain particle size data.

5. Concentration Ranges

New provisions allow chemical manufacturers to use concentration ranges when claiming trade secrets.

Compliance Timeline for OSHA’s HazCom Updates

OSHA has extended the compliance deadlines compared to the original proposal. The final rule becomes effective on July 19, 2024:

• Manufacturers of Substances: 18-month compliance deadline
• Manufacturers of Mixtures: 36-month compliance deadline

Employers must adapt their workplace hazard communication practices (e.g., updating workplace labels, written HazCom plans, and worker training) within six months after the respective manufacturer deadlines for substances and mixtures.

Steps to Prepare for Updated HazCom Requirements

1. Review and Update Chemical Inventory: Ensure your chemical inventory reflects compliance with the new classification criteria.
2. Revise SDS Library: Update SDSs to align with the new requirements, particularly regarding classification criteria and additional information.
3. Train Employees: Provide training to workers on the new labeling requirements and updated hazard communication practices.
4. Adapt Labeling Practices: Implement changes to workplace labels and ensure that small container labeling aligns with the new provisions.
5. Monitor Compliance: Establish a system to track compliance with the new deadlines and regulations, including keeping abreast of any future OSHA updates.
6. Engage with Suppliers: Communicate with your chemical suppliers about the new HazCom requirements and ensure they are also compliant.

The changes introduced in this HazCom final rule, while not as extensive as the 2012 updates, require careful attention to detail regarding specific chemical hazard classes and related classification and information practices. Preparing now will help ensure compliance and maintain a safe working environment.