The Occupational Safety and Health Administration (OSHA) has officially updated its Hazard Communication Standard (HCS) to align with the 7th revision of the United Nations’ Globally Harmonized System (GHS), with select provisions from the 8th revision.
These changes aim to improve chemical hazard communication, enhance worker protection, and streamline compliance across borders.
Key Highlights of the New HazCom Rule
The updated Hazard Communication Standard (HCS) aims to improve the clarity and completeness of hazard information on labels and Safety Data Sheets (SDSs), with a particular focus on small containers and complex chemical mixtures. These changes apply broadly to chemical manufacturers, importers, distributors, and employers.
Among the most notable updates to SDSs are the expanded hazard classifications, which now include new categories such as flammable gases, aerosols, desensitized explosives, and chemicals under pressure. Additionally, Section 2 of the SDS must now include hazards that could arise from foreseeable chemical reactions. Section 3.2 allows the use of standardized concentration ranges to protect proprietary formulations, and Sections 7 and 9 require more detailed information regarding chemical storage and physical properties.
Labeling Requirements
- Small Containers:
- ≤100 ml: Must include product identifier, pictogram, signal word, manufacturer info, and reference to full label on outer packaging.
- ≤3 ml: Only product identifier required.
- Mixtures:
- Must be reclassified and relabeled based on new hazard definitions and end-use scenarios (e.g., salon products under heat exposure).
Real-World Example:
Scenario: A restaurant uses a commercial degreaser in the kitchen, stored in small spray bottles for convenience.
Old Practice: The spray bottles were labeled with handwritten notes or generic stickers.
New Requirement:
- If the bottle is ≤100 ml, it must now include:
- Product identifier (e.g., “Citrus Degreaser”)
- Pictogram (e.g., corrosive symbol)
- Signal word (e.g., “Danger”)
- Manufacturer contact info
- Reference to the full label on the outer packaging
Why It Matters:
Kitchen staff may be exposed to concentrated chemicals during cleaning. Proper labeling ensures they understand the risks (e.g., skin burns, respiratory irritation) and know how to respond in case of exposure.
Compliance Deadlines
| Date | Requirement | Who Must Comply |
|---|---|---|
| Jan 19, 2026 | Update SDSs and labels for substances | Manufacturers, importers, distributors, employers |
| Jul 19, 2026 | Update workplace labels, training, and programs for substances | Employers |
| Jul 19, 2027 | Update SDSs and labels for mixtures | Manufacturers, importers, distributors, employers |
| Jan 19, 2028 | Update workplace labels, training, and programs for mixtures | Employers |
What Employers Should Do Now
- Review all chemical inventories and SDSs.
- Update hazard communication programs and training materials.
- Coordinate with suppliers to obtain revised SDSs.
If you have any questions about workplace safety, contact Ray Sullivan.
Please see our resource page for accident prevention strategies.