The most significant update to U.S. chemical safety regulations in over a decade brings substantial changes to classification, labelling, and documentation requirements. Philip Mole of VelocityEHS outlines the key updates and compliance deadlines that manufacturers and downstream users must prepare for starting next year.
For workplaces where employees may be exposed to hazardous chemicals, the Hazard Communication Standard (HazCom) remains one of the most critical regulations businesses must adhere to. However, compliance with HazCom is more than just a regulatory requirement—it is a fundamental step in ensuring that every worker returns home safely at the end of the day.
Since its introduction by OSHA in 1983, HazCom has been a cornerstone of workplace safety. Now, with newly implemented requirements rolling out on a phased-in compliance schedule, the standard has been further strengthened to enhance hazard communication and improve worker protection.
For more than 40 years, HazCom has established essential standards and procedures to ensure that chemical manufacturers and suppliers properly classify chemicals and provide crucial hazard information to downstream businesses. The primary goal has always been to equip workers with the knowledge they need to handle hazardous chemicals safely, minimising risks in storage and use. Over time, HazCom has played a significant role in protecting worker health and safety, saving countless lives and preventing tens of thousands of chemical-related injuries by reducing workplace exposures.
Despite its effectiveness, HazCom had certain limitations. One of the main challenges was the inconsistency in how chemical manufacturers presented hazard information. Variations in pictograms on container labels and the inconsistent formatting of material safety data sheets (MSDSs) made it difficult for end users to quickly identify chemical hazards and locate critical safety information in the event of a spill or exposure.
To address these issues, OSHA aligned HazCom with Revision 3 of the United Nations’ Globally Harmonised System of Classification and Labeling of Chemicals (GHS) in 2012. This update standardised the format of safety documentation—now referred to as safety data sheets (SDSs)—and introduced a uniform set of pictograms for container labels, making hazard communication clearer and more effective.
The updated HazCom rule mostly aligns with GHS Revision 7 and select elements of Revision 8. HazCom 2024 introduced changes across multiple facets of the standard, including:
- 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.
While this alignment improved the accuracy and accessibility of hazard information, the GHS has continued to evolve, with updates introduced by a UN subcommittee every two years. Recognising the need to keep pace with these advancements, OSHA began planning a new update to HazCom in 2018. By 2021, the agency proposed revised HazCom rules, incorporating feedback from industry stakeholders before finalising the updated regulation in 2024.
