OSHA Proposes Rule to Update the HCS

OSHA Proposes Rule to Update the HCS

The Occupational Safety and Health Administration’s (OSHA) Hazard Communication Standard (HCS) outlines requirements regarding labels and Safety Data Sheets (SDSs) for hazardous workplace chemicals throughout the United States. To align its requirements with the United Nation’s Globally Harmonized System of Classification and Labeling of Chemicals (GHS), OSHA recently issued a proposed rule to update the HCS.

The HCS was last modified in 2012, in order to match GHS Revision 3. OSHA’s proposed rule would update the requirements within the HCS to conform with GHS Revision 7—which debuted in 2017. Key HCS changes that would result from the proposed rule include:

  • Revised classification criteria—The HCS’s criteria for the classification of health and physical hazards would change under OSHA’s proposed rule. This includes revised health hazard definitions, changes to sections on skin corrosion and serious eye damage, updates to the flammable gases hazard class, an expansion of the flammable aerosol hazard class and the addition of a new physical hazard class.
  • Relaxed requirements for updating labels—The current HCS requires labels to be physically updated after new information regarding chemical hazards arises. However, OSHA’s proposed rule would allow new labels for chemicals awaiting future distribution to either be placed on containers, included within shipping papers or sent via electronic means.
  • New provisions for small containers—In scenarios where it’s not feasible to include full label information on small chemical containers, OSHA’s proposed rule would permit reduced information labels.
  • Amendments to the contents of labels and SDSs—OSHA’s proposed rule would require labels to include the date that chemicals are released for shipment. It would also require several adjustments to SDSs.
  • Changes to HCS definitions—Lastly, OSHA’s proposed rule would update three existing terms and introduce eight new definitions to the HCS.

Together, these HCS changes will help remedy remaining issues that employers, manufacturers and importers have encountered since the 2012 HCS modification.

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