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Key Updates in Hazard Communication Standards

Aligning with Global Standards

OSHA’s Hazard Communication Standard has undergone key revisions to improve workplace safety and ensure clear, consistent communication about chemical hazards. These updates align OSHA’s HazCom standards with the Globally Harmonized System (GHS) Revision 7, bringing greater consistency to how chemical information is classified and labeled worldwide.

With each revision, OSHA refines its approach to hazard communication to reflect scientific advancements and industry best practices. These updates aim to enhance worker protection, streamline compliance efforts, and improve international trade by ensuring that chemical hazards are universally understood.

Standardized Safety Data Sheets (SDS)

One of the most significant updates is the standardized format for Safety Data Sheets (SDS). Formerly known as Material Safety Data Sheets (MSDS), SDS now follows a consistent 16-section format to make locating essential safety information—such as handling, storage, and first aid—quick and straightforward.

Pro Tip #1: If you're used to working with MSDS, take time to familiarize yourself with the SDS format. The structured sections allow for faster and more efficient hazard identification.

Each SDS section provides specific details about the chemical, including:

  1. Identification – Chemical name, manufacturer details, and recommended use.
  2. Hazard Identification – Classification of hazards, required pictograms, and signal words.
  3. Composition/Information on Ingredients – Chemical composition and trade secret details.
  4. First-Aid Measures – Immediate response actions for exposure.
  5. Firefighting Measures – How to control chemical fires.
  6. Accidental Release Measures – Procedures for spill containment and cleanup.
  7. Handling and Storage – Proper storage and precautions.
  8. Exposure Controls and PPE – Required protective equipment.
  9. Physical and Chemical Properties – Characteristics such as boiling points and solubility.
  10. Stability and Reactivity – Information on reactivity and hazardous decomposition products.
  11. Toxicological Information – Health effects and exposure risks.
  12. Ecological Information – Environmental impact data.
  13. Disposal Considerations – Proper waste management and disposal.
  14. Transport Information – Guidelines for safe transportation.
  15. Regulatory Information – Compliance with federal, state, and local laws.
  16. Other Information – Additional relevant safety details.

Note: Sections 12–15 are required under GHS but are not enforced by OSHA.

Trade Secret Concentration Ranges

To balance worker safety and proprietary protections, OSHA now permits the use of prescribed concentration ranges for trade secrets instead of exact values. This change aligns with Health Canada’s WHMIS and other international standards, promoting transparency while safeguarding confidential formulations.

Pro Tip #2: In a medical emergency, chemical manufacturers must disclose exact ingredient concentrations to a licensed medical professional upon request for treatment purposes—even if the ingredient is otherwise protected as a trade secret.

New & Updated Definitions

To enhance clarity and improve hazard communication, OSHA has introduced new definitions and refined existing ones:

New Definitions:

  • Bulk Shipment – Large quantities of hazardous materials shipped without packaging.
  • Combustible Dust – Finely divided particles that can ignite under specific conditions.
  • Solid, Liquid, and Gas – Standardized definitions to improve classification consistency.
  • Immediate Outer Package – The first level of packaging that encloses a hazardous material.
  • Physician or Other Licensed Health Care Professional (PLHCP) – Defines medical professionals responsible for workplace exposure evaluations.
  • Released for Shipment – Specifies when a product is considered ready for transportation.

Revised Definitions:

  • Exposure or Exposed – Clarifies how workers may come into contact with hazardous chemicals.
  • Hazardous Chemical – Refined to align with the latest toxicology and chemical safety research.
  • Physical Hazard – More precise criteria for identifying fire, explosion, and reactivity risks.

Changes to Hazard Classifications

Several modifications have been made to hazard classifications to improve worker understanding and ensure better safety standards:

  • Aerosols: Now includes a new category for non-flammable aerosols, expanding beyond the previous focus on flammable aerosols.
  • Desensitized Explosives: Introduced as a new hazard class to improve classification of chemically stabilized explosives.
  • Flammable Gases: Now incorporates pyrophoric gases into the category rather than listing them separately.

Pro Tip #3: These updates ensure better hazard classification and global trade consistency. Workers should review SDS updates to stay informed on any new risks.

State Plan Adoption & Business Impact

All state plans must adopt provisions that are at least as effective as OSHA’s revised HazCom standard. This ensures a uniform safety standard across the country. Additionally, these updates are expected to generate an estimated net cost savings of $29.8 million annually by streamlining compliance while improving worker protection.

Employers must update workplace safety programs to align with these revisions, ensuring that SDSs, labeling systems, and training materials reflect the latest standards. Businesses benefit from these changes by reducing regulatory confusion, improving hazard recognition, and ensuring safer workplaces.

Your Right to Understand

These updates reinforce OSHA’s shift from "Right to Know" to "Right to Understand"—ensuring that workers are not just aware of hazards but can effectively interpret and act on chemical safety information.

Pro Tip #4: If you’re unsure about a classification or label change and aren't sure what it means, don’t assume it’s minor. Check the SDS, ask your supervisor, or consult OSHA’s 29 CFR 1910.1200 guidelines for clarification.

Clarification Update: In October 2024, OSHA issued technical corrections to HazCom 2024. These included corrections to dermal toxicity thresholds, classification cutoffs for reproductive hazards, and updated hazard statements for “chemical under pressure.” While minor, these changes ensure full alignment with OSHA’s intent and international standards.