OSHA Revises the Hazard Communication Standard

The Occupational Safety and Health Administration (OSHA) Hazard Communication Standard (HCS) final rule was published May 20, 2024, in the Federal Register. This OSHA 2024 update amends the HCS to conform to the United Nations’ Globally Harmonized System of Classification and Labelling of Chemicals (GHS). The intention of the 2024 HCS final rule is to enhance worker safety through better communication on chemical hazards.

Since its inception in 1983, the HCS has provided comprehensive information on workplace chemicals, but it allowed flexibility in label and safety data sheet formats. While this flexibility has been beneficial, a standardized approach offered by the GHS will be more effective. The GHS includes specific criteria for classifying hazards and standardized label elements, improving understanding and safe handling of chemicals.

What You Need to Know

The new Hazard Communication Standard mandates a consistent format for safety data sheets, making information more accessible for employers, workers, health professionals, and emergency responders. This standardized approach will also harmonize communication with international partners, reducing confusion from varying national and international requirements. Adoption of the GHS globally will ensure that chemicals crossing borders have consistent, clear hazard information, improving global safety and communication.

The updated HCS is an amendment to the current standard. Elements of the standard not associated with the GHS, such as its fundamental structure, scope, and exemptions, have mostly remained the same. Some terms have been updated to align the revised HCS with the GHS terminology. For instance, “hazard determination” is now “hazard classification,” and “material safety data sheet” has been updated to “safety data sheet.” This approach received positive feedback from OSHA stakeholders.

Key Updates to the HCS

The OSHA HCS was updated on May 20, 2024, and will take effect on July 19, 2024. The revisions aim to improve the standard’s effectiveness by providing more information to workers and first responders about chemical hazards in the workplace. In addition, the 2024 HCS update also addresses issues that arose during the implementation of the 2012 standard and aims to align with other federal agencies and international trading partners.

The 2024 HCS updates include:

• Labeling requirements for small packaging have been updated to ensure labels are comprehensive and readable. Labels must be legible, in English, and prominently displayed, but other languages may also be used.
• A new hazard class, desensitized explosives, has been added, as well as new hazard categories for chemicals under pressure within aerosols and unstable gases in flammable gases.
• New definitions have been added for bulk shipment, combustible dust, gas, liquid, solid, immediate outer package, physician, or other licensed health care professional (PLHCP) and released for shipment.
• Rules for trade secrets on SDS have been revised. Manufacturers will be required to disclose the concentration range in which a secret concentration falls, using a specified list of narrow ranges currently used by Health Canada.
• Employers will have the option not to relabel chemicals released for shipment if new hazards are identified, but they will need to provide an updated label with the shipment.

While the new GHS standard does not set harmonized training requirements, it acknowledges the importance of training in effective hazard communication. The revised Hazard Communication Standard (HCS) mandates that workers be retrained within two years of the final rule’s publication to ensure they can recognize and understand the new labels and safety data sheets.

Hazard Communication Standard Training

Finally, let’s talk about training! HCS has always been intended to ensure that employees understand how to take the appropriate precautions and use protective measures to avoid chemical exposure and workplace injuries. The requirements for HCS training are outlined in OSHA regulation 29 CFR 1910.1200(h). With significant revisions to OSHA’s HCS regulations taking effect in July 2024, it is essential to update the training to ensure employees can continue to recognize and protect themselves from hazardous chemicals in the workplace.

How to Make Hazard Communication Standard Training More Valuable

Has your HCS training become mundane? Don’t you want the information to make an impact so that you can keep workers knowledgeable and alert about handling hazardous chemicals during their job? Here are some of the things I use to keep HCS interesting and relevant:

• Incorporate quizzes, interactive modules, and hands-on activities.
• Use real-life scenarios to demonstrate the importance of HCS training.
• Create visually appealing Safety Data Sheets (SDSs) and labels.
• Share case studies of chemical incidents in similar workplaces.
• Discuss lessons learned from past accidents and near-misses.
• Conduct live demonstrations of proper handling and storage of chemicals.
• Show the correct use of personal protective equipment (PPE).
• Offer refresher courses to keep information current and top-of-mind.
• Encourage employees to share their experiences and best practices.
• Gather feedback from employees about the training process.
• Ask for training feedback and adjust the training program based on their suggestions and needs.
• Ensure easy access to SDSs and other safety resources.
• Provide digital tools and apps for quick reference and learning on-the-go.

Hands-On Learning is Key

It is important to make HCS training relevant to the work while doing their job. Many companies use online HCS training that covers the general aspects required by the HCS standard but fails to show the employee how it directly applies to the chemicals and handling procedures in their everyday work. Do you want the information to “hit home”? Then make sure you do what’s right for your employees and implement some type of hands-on learning, in-person coaching, and/or skills check.

Employee knowledge of the HCS and SDS is an important part of workplace safety because it empowers workers to identify and understand the risks associated with hazardous chemicals, ensuring their safety and health in the workplace. Proper training enables employees to read and interpret chemical labels and SDSs accurately, apply appropriate precautions, and use protective measures to prevent exposure and injuries.

This knowledge not only helps in maintaining a safe work environment but also ensures compliance with OSHA regulations, reducing the risk of chemical-related incidents and promoting a culture of safety.

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About the Author

James A. Junkin, MS, CSP, MSP, SMS, ASP, CSHO is the chief executive officer of Mariner-Gulf Consulting & Services, LLC and the chair of the Veriforce Strategic Advisory Board and the past chair of Professional Safety journal’s editorial review board. James is a member of the Advisory Board for the National Association of Safety Professionals (NASP).   He is Columbia Southern University’s 2022 Safety Professional of the Year (Runner Up), a 2023 recipient of the National Association of Environmental Management’s (NAEM) 30 over 30 Award for excellence in the practice of occupational safety and health and sustainability, and the American Society of Safety Professionals (ASSP) 2024 Safety Professional of the Year for Training and Communications, and the recipient of the ASSP 2023-2024 Charles V. Culberson award. He is a much sought after master trainer, keynote speaker, podcaster of The Risk Matrix, and author of numerous articles concerning occupational safety and health.