Complying with OSHA’s Evolving Hazard Communication Standard: 2022 Update

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OSHA’s Hazard Communication Standard (HCS), first published in 1983, is designed to ensure that both employers and workers know about and can recognize hazardous chemicals in the workplace and take appropriate measures to protect themselves. The standard requires safety data sheets, labels, and employee training.

Revisions to OSHA's Hazard Communication Standard

In 2003, the United Nations adopted the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The GHS includes criteria for the classification of health, physical and environmental hazards, as well as specifying which information should be included on labels of hazardous chemicals as well as safety data sheets (SDS).

In 2009, OSHA aligned its Hazard Communication Standard with the United Nation’s GHS, which is updated with improvements and clarifications every two years. As a result, OSHA must also regularly update its own standard to remain in alignment with the GHS.

Most recently, in 2021, OHSA issued a proposed rule to adhere to Revision 7 of the GHS, which would further improve the information on labels and safety data sheets for hazardous chemicals and help employees recognize and understand the updated standards.

Like all OSHA proposed rules, the new standard is designed to increase worker protections and to reduce the incidence of chemical-related occupational illnesses and injuries.

What Is the Proposed Rule Change?

According to OSHA, the major changes to the hazard communication standard include:

  • Hazard classification: Provides specific criteria for the classification of health and physical hazards, as well as the classification of mixtures.
  • Labels: Chemical manufacturers and importers will be required to provide a label that includes a harmonized signal word, pictogram, and hazard statement for each hazard class and category. Precautionary statements must also be provided.
  • Safety Data Sheets: Will now have a specified 16-section format.
  • Information and training: Employers are required to train workers on the new labels, elements, and safety data sheets format to facilitate recognition and understanding.

Specifically, the proposed rule change makes changes to Appendices A (Health Hazard Criteria), B (Physical Criteria), C (Allocation of Label Elements), and D (Safety Data Sheets) of the HCS:

  • Appendix A will contain revised health hazard definitions, updated skin corrosion/irritation and serious eye damage/irritation chapters along with general updates to hazard classes.
  • Appendix B will have new gas categories (pyrophoric and unstable gases) under flammable gases, a new chapter for Desensitized Explosives, and new categories for aerosols.
  • Appendix C will be revised to include new hazards and updated guidance and precautionary statements.
  • Appendix D will contain updates to Sections 9 and 11 of the SDS.

How Will OSHA’s Updated Hazard Communication Standard Impact Employers?

According to OSHA’s preliminary Economic Analysis, the proposed updates would result in modest, non-quantifiable improvements in worker health and safety above those already achieved under the current HCS.

For every affected industry, the proposed rule would provide either cost savings or the costs would be less than one percent of revenues or ten percent of profits. For small/very small entities in any industry, the proposed rule would not impose costs more than one percent of annual revenues or five percent of annual profits.

When Will the New Standard Be Effective?

OSHA opened a forum for public comment until May 19, 2021, and held public hearings in late September. Now that the comments are in, OSHA will work on finalizing the new rule.

OSHA experts expect the proposed changes to be implemented over a two-year period. Before the new standard becomes effective, OSHA will announce the revised rule and give employers sufficient time to establish compliance.

In the meantime, employers should continue to comply with the current standard, while anticipating the new rule and discuss compliance with their OSHA compliance and training team.

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