The Occupational Safety and Health Administration (OSHA) has updated its Hazard Communication Standard to more closely align with the revised Globally Harmonized System (GHS). The updated standard breaks hazards into solids, liquids, gases, and combustible dusts and accounts for changes in a chemical’s physical form. OSHA also added small container labeling requirements and allowed for concentration ranges to be used to protect trade secrets.
These updates will require chemical manufacturers, importers, and distributors to make some changes to the labels and safety data sheets for their chemicals. This will, in turn, require employers to update their labels, hazard communication programs, and employee training once they get that updated information.
While the updated standard takes effect on July 19, 2024, there is a transition period for compliance. Chemical manufacturers, importers, and distributors evaluating substances (chemicals in their natural state) have until January 19, 2026, to become compliant. Employers then have until July 20, 2026, to update workplace labeling, revise their hazard communication program, and provide additional employee training.
Chemical manufacturers, importers, and distributors evaluating mixtures (combinations of substances) have until July 19, 2027, to become compliant. Employers then have until January 19, 2028, to update workplace labeling, revise their hazard communication program, and provide additional employee training.
Employers Council can help you better understand these changes. If you have any questions, please contact us.
Jennifer Vold is an attorney for Employers Council.