Understand Key Updates to the Hazard Communication Standard
Legislation to abolish the Occupational Safety and Health Administration (OSHA) was introduced on Jan. 3, 2025. The bill, called the Nullify Occupational Safety and Health Administration Act, has been nicknamed “NOSHA.”
While OSHA’s fate hangs in the balance, its mission “to assure America's workers have safe and healthful working conditions free from unlawful retaliation,” carries on.
OSHA finalized an updated version of the Hazard Communication Standard (HazCom) late last year. HazCom has played a vital role in workplace safety for over 40 years by ensuring chemical manufacturers properly communicate hazard information to businesses using their products.
While successful in preventing numerous injuries and deaths, HazCom initially struggled with inconsistent pictograms and varying formats for material safety data sheets, making it challenging for users to quickly identify hazards and access safety information, according to an article in Corporate Compliance Insights.
In 2012, OSHA aligned HazCom with the UN's Globally Harmonized System (GHS) Revision 3, standardizing both safety data sheets and container label pictograms. This significantly improved hazard communication clarity and consistency.
The article’s author, Philip Mole of VelocityEHS, participated in a Chemical Processing Distilled podcast where he stressed the need for ingredient-level visibility of hazardous chemicals.
“Everybody is affected by the chemicals that you're using. That starts with you; it starts with having the information that you need about the chemicals that exist at the ingredient level, that are not being hidden by chemical names,” Mole said in the podcast.
The Corporate Compliance Insights article highlighted key updates.
- Hazard classes and classifications: The updates change the way HazCom classifies some chemicals (particularly aerosols, desensitized explosives, flammable gases and chemicals under pressure), which changes some of the information manufacturers must provide on the SDSs and shipped container labels for those chemicals. As a result, these changes also affect the precautions and workplace HazCom practices for employers who have the affected chemicals in their workplaces.
- Labeling requirements: Labeling rules have changed, with new allowances and requirements for containers OSHA defines as “small” or “very small” chemical containers.
- Updated classification guidance: The 2024 version of HazCom includes more specific guidance on how manufacturers should classify chemical substances and the analytical methods they can use.
- Expanded SDS content: Safety data sheets, which register information about chemicals, must now provide additional data, such as “particle characteristics,” in Section 9.
- Classification based on intrinsic hazards: Chemical manufacturers must include information about chemical hazards from known or reasonably anticipated downstream uses of their products in their classification and include the information in Section 2 of the SDS.
