Did you know that your SDSs may need to be updated to be compliant with the new regulations?
On May 20, 2024, the U.S. Occupational Safety and Health Administration (OSHA) issued a final rule amending the Hazard Communication Standard (HCS) to align with the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS), primarily adopting elements of Revision 7. The revisions are intended to enhance the clarity and effectiveness of hazard communication, improve consistency with international requirements, and address implementation issues identified since OSHA’s 2012 GHS adoption.
Key Changes
The final rule introduces a range of updates, including:
- Hazard classification methodology.
- Label generation, particularly for small containers and revised hazard statements.
- Safety Data Sheets requirements
- Physical hazard determinations for aerosols, chemicals under pressure, pyrophoric gases, and desensitized explosives.
- Confidential Business Information (CBI) through prescribed concentration ranges.
- Mixture classifications involving ingredients with unknown acute toxicity.
The final rule became effective on July 19, 2024. Compliance deadlines vary by chemical type (substances vs. mixtures) and by stakeholder role, as outlined below.
What This Means for You
Although the HazCom 2024 revisions are less extensive than OSHA’s 2012 GHS adoption, many manufacturers will need to review existing hazard classifications, SDSs, and labels to ensure compliance with the updated requirements. With the May 19, 2026 compliance deadline for substances now passed, manufacturers, importers, and distributors should ensure that all hazardous substance SDSs and labels have been updated to meet the revised HazCom 2024 requirements.
Attention should now shift toward the upcoming November 20, 2026 employer compliance deadline. Employers should review and update their written Hazard Communication programs, workplace labeling, and employee training to ensure alignment with the revised hazard information for substances. Planning should also begin for the November 19, 2027 manufacturer deadline for hazardous mixtures, which will typically require a more comprehensive review of formulations, mixture classifications, labels, and Safety Data Sheets, followed by the corresponding employer implementation activities.
Taking a proactive approach now will help avoid last-minute compliance challenges and ensure a smooth transition to the revised standard.
Trinity Consultants Hazard Communication Support
Trinity Consultants offers comprehensive hazard communication support, including hazard classification reviews, OSHA HazCom 2024 gap assessments, SDS authoring and updates, label development, global SDS compliance reviews, and regulatory consulting. Our team supports chemical, pharmaceutical, biotechnology, food and beverage ingredients, energy, and industrial clients worldwide.
Whether you require assistance with OSHA compliance, international GHS implementation, or global SDS authoring, Trinity can help ensure your hazard communication program remains current and compliant. Please contact Amanda Tuesdale for additional information regarding our HazCom and SDS services.
