OSHA’s Hazard Communication Update: What you need to know

The Department of Labor (DOL) announced a final rule to take effect on July 19, 2024, which will update the Hazard Communication Standard, administered by the Occupational Safety and Health Administration (OSHA). The previous version of the Hazard Communication had not been revised since its initial publication in 2012, so the goal was to address issues and concerns that have risen since its original publication. The goal is to enhance worker safety by improving clarity and comprehensiveness of chemical hazard information.

Here are the key updates:

1. Alignment of hazard classifications with the 7^th revision of the United Nations’ Globally Harmonized System (GHS) of Classification and Labelling of Chemicals.
2. Updated definitions for bulk shipments, combustible dust, gas, immediate outer package, liquid, physician or other licensed health care professional, released for shipment, and solid.
3. Hazard classification must now include hazards from a change in the chemical’s physical form and chemical reaction products associated with known or reasonably anticipated use or application.
4. Labels for bulk shipments must be on the immediate container, transmitted with the shipping papers / bills of lading, or with the agreement so it’s immediately available to workers on the receiving end of the shipment.
5. There is an option to not have to relabel those as long as the updated label for each container is provided with each shipment for chemicals that have already been released for shipment and are awaiting distribution.
6. New minimum label requirements for containers that are 100ml and less or 3ml and less.
7. Mandatory use of prescribed concentration ranges for materials that are considered trade secrets.

Manufacturers, importers, and distributors must comply with the new requirements by January 19, 2026, for substances and by July 19, 2027, for mixtures.

Employers’ should complete the following next steps to prepare for compliance;

1. Understand the OSHA Hazard Communication Standard.
2. Assign responsibility to a competent person to meet all obligations.
3. Conduct a hazardous chemicals inventory to maintain accuracy.
4. Obtain and review Safety Data Sheets (SDS). These must be kept current and accessible to employees.
5. Update labels and warnings as manufacturers comply with the new requirements.
6. Revise your written Hazard Communication program to reflect any changes.
7. Update training materials with regulations and chemical hazards.
8. Engage employees in the process to ensure they understand and follow safety protocols.

Employers have specific compliance deadlines to meet, and it is crucial to update training materials to prioritize the safety of their workers.