The Occupational Safety and Health Administration (OSHA) has introduced significant updates to the Hazard Communication Standard (HCS), transitioning from HCS 2012 to HCS 2024.

These updates aim to align with the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS) Revision 7 and enhance the clarity and effectiveness of hazard communication. This article will explore the key changes in labels, safety data sheets, and hazard classification.

Key Changes in Labeling Requirements

The new HCS 2024 introduces several important updates to labeling requirements that are intended to update the information to be more relevant to those who will use it. There are a number of key changes to be aware of.

Expanded Label Information:

The updated standard requires more detailed labeling on shipped containers, including product identifier, signal word, hazard statement(s), pictogram(s), precautionary statement(s), and the name, address, and telephone number of the responsible party. Labels now must also address hazards identified and classified under (d)(1)(ii).

Small Container Labeling:

For containers smaller than 100 ml, a simplified label is permitted, which includes the product identifier, pictogram(s), signal word, and the manufacturer’s name and phone number.

For containers 3 ml or smaller, only the product identifier is required, provided it does not interfere with the container’s use.

Bulk Shipments:

Labels for bulk shipments can be transmitted electronically or with shipping papers, ensuring they are available to workers at the receiving end.

Label Updates:

Manufacturers must update labels within six months of becoming aware of significant new information regarding chemical hazards.

Purpose of Updating Labeling Requirements

These changes aim to ensure that labels provide comprehensive and accessible information, improving safety for workers handling hazardous chemicals.

Enhancements to Safety Data Sheets

The safety data sheets (SDS) have also undergone notable revisions under HCS 2024. Some of the changes that are most significant include the following.

Standardized Format:

The SDS must continue to follow a standardized 16-section format, which is now more detailed to ensure consistency and completeness of information.

Accessibility:

Employers must ensure that SDS are readily accessible to employees during their work shifts. The information can be stored in various forms, including digital formats, provided it is easily accessible.

Group Hazard Information:

SDS can now cover groups of hazardous chemicals if addressing the hazards of a process rather than individual chemicals is more appropriate. This is particularly useful in environments where multiple chemicals are used in conjunction.

How Will the Updates to Safety Data Sheets Help

These enhancements to the SDS are designed to provide clearer, more detailed information to workers, thereby improving their ability to handle chemicals safely and respond to emergencies.

Broadened Scope for Hazard Classification

The process for hazard classification has also been refined and expanded in HCS 2024. Key areas to be aware of include the following.

Intrinsic Properties and Use-Related Hazards:

Chemical manufacturers and importers are required to evaluate not only the intrinsic properties of chemicals but also hazards associated with changes in physical form and chemical reactions during expected uses.

Detailed Criteria:

The criteria for classifying physical hazards have been updated to include new hazard classes such as desensitized explosives and pyrophoric gases. These updates provide clearer guidelines for identifying and communicating potential risks.

Consistent Classification:

The new rules aim to ensure that hazard classifications are consistent and thorough, providing a more comprehensive understanding of chemical risks.

Improvements Resulting from These Changes

By broadening the scope of hazard classification, HCS 2024 ensures that all potential risks are identified and communicated, enhancing workplace safety.

The Importance of Keeping up with Hazard Communication Standard Changes

The updates to the Hazard Communication Standard (HCS) 2024 reflect OSHA’s commitment to improving workplace safety by aligning with the latest global standards and addressing emerging chemical hazards.

The changes in labels, safety data sheets, and hazard classification are designed to provide clearer, more detailed information, making it easier for employers and workers to understand and manage chemical risks effectively. Adapting to these new requirements will be crucial for maintaining compliance and ensuring a safe working environment.