OSHA Updates Its Hazard Communication Standard

On May 20, 2024, the Occupational Health and Safety Administration (OSHA) published several revisions to its Hazard Communication Standard (HCS). The HCS is one of the cornerstones of any safety program as it primarily addresses chemical hazards and precautions to protect employees from those hazards.

OSHA revised the standard to better align HCS with the 7th revision of the United Nations’ Globally Harmonized System of Classification (GHS). This standard was last updated in 2012 to align with revision 3 of the GHS. Along with these revisions come a slew of regulatory requirements for manufacturers, importers, distributors, and downstream users. Downstream users and employers, where most printers would fall, may need to update their hazard communication program, workplace labels, SDSs, and training. The rule’s effective date is July 20, 2024, but OSHA has provided a grace period when impacted facilities can comply with the previous version of HCS or the final rule.

Manufacturers and importers of chemical substances or mixtures will be most impacted by OSHA’s updated HCS standard. They must review their chemical classifications to determine if any revisions to the HCS criteria require updates to their chemical labels and/or safety data sheets (SDSs). OSHA expects that distributors will continue to rely on the labels and SDSs provided by manufacturers. However, if a distributor relabels or replaces the manufacturers’ or importers' information with their own, they must comply with the same HCS requirements. Some of the new requirements under the revised HCS include:

New and Revised Definitions

  • OSHA added definitions to terms related to classification of physical states (e.g., solid, liquid, or gas), combustible dust, and shipping labeling requirements.
  • OSHA revised the definitions for exposure or exposed, hazardous chemical, and physical hazard.

Labels

  • The agency made changes to the labeling requirements for small and bulk containers. Manufacturers have six months since becoming aware of necessary changes to update the labels. However, OSHA is allowing them to use the old label on materials already packaged and labeled if they provide the updated label for each container shipped.
  • OSHA also updated their guidance on how to apply elements to a label including that a pictogram should appear once.  

Safety Data Sheets

  • OSHA made several changes to SDSs including that the address and telephone number in Section 1 must be in the U.S. and clarified that exposure limits in Section 8 must be included for all ingredients listed in Section 3.

Health Hazards

  • OSHA made significant changes to several health hazard classes including revisions to the sections on skin corrosion/irritation and serios eye damage/irritation. Non-animal test methods were added to skin corrosion/irritation. Even with the changes to the health hazard criteria, the agency does not expect changes in the classification of existing chemicals.

Physical Hazards

  • OSHA has implemented extensive changes to several of the physical hazard classes. The agency does expect there to be some reclassification of hazards although no new hazardous chemicals are expected to be identified. Most of the changes will affect flammable gases, aerosols, oxidizing solids, and a new category: desensitized explosives.

OSHA has established several deadlines and although a grace period was provided, members are encouraged to begin compliance efforts right away. Printers and suppliers should begin to contact their vendors and inquire if any of the chemicals they provide will have changes under the new standard. Members should then review their chemical inventories, labels, SDSs, written programs, and training to ensure they are aligned with the new standard.

The table below outlines the compliance dates set by OSHA:

Compliance DateRequirementType of Facility
January 19, 2026Update labels and SDSs for substances*Chemical manufacturers, importers, distributors, and employers
July 20, 2026Update workplace labels, hazard communication program, and training as necessary for substances*Employers
July 19, 2027Update labels and SDSs for mixtures**Chemical manufacturers, importers, distributors, and employers
July 19, 2028Update workplace labels, hazard communication program, and training as necessary for mixtures**Employers
May 20, 2024 - deadlineMay comply with old or new standardChemical manufacturers, importers, distributors, and employers
*Substance: has a definite homogenous composition

**Mixture: combination of 2 or more substances where each retains its chemical identity

The Environmental, Health, and Safety (EHS) team at PRINTING United Alliance is reviewing the new standard. The Alliance will update the Hazcom site and written program template if necessary and will provide an update when completed. Members are encouraged to reach out to Sara Osorio (sosorio@printing.org) or Gary Jones (gjones@printing.org) with any HCS related questions.

In this article, Sara Osorio, Coordinator, EHS Affairs, PRINTING United Alliance, reviews OSHA’s new Hazard Communication Standard. More information about this and other compliance issues can be found at Business Excellence-EHS Affairs, or reach out to Sara directly if you have questions about how these issues may affect your business: sosorio@printing.org.   
  
To become a member of the Alliance and learn more about how our subject matter experts can assist your company with services and resources such as those mentioned in this article, please contact the Alliance membership team: 888-385-3588 / membership@printing.org.

 

Sara Osorio Environmental, Health and Safety Affairs Coordinator

Sara Osorio is the Environmental, Health and Safety (EHS) Affairs Coordinator at PRINTING United Alliance. Her primary responsibility is to assist members with EHS regulatory compliance, sustainability, and EHS consulting. Sara also monitors the EHS regulatory activities at the federal and state-level that impact the printing industry including those occurring at Environmental Protection Agency (EPA), the Occupational Health and Safety Administration (OSHA), the Department of Transportation (DOT), and other agencies. She develops guidance material for members, gives presentations, and writes articles on EHS regulations and sustainability issues. She also supports the Sustainable Green Printing Partnership and Alliance members in their efforts to certify printing operations in sustainable manufacturing.

Sara received a Bachelor of Science in Environmental Studies from Florida International University and is pursuing and Master of Science in Sustainable Management from the University of Wisconsin – Green Bay.

Speaking Topics:

  • Regulatory compliance and sustainability
  • Webinars on a wide variety of EHS related topics
  • Customized seminars and workshops
  • Employee training on safety and environmental compliance
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