March 2012 – OSHA Revises Hazard Communication Standard

OSHA Revises Hazard Communication Standard

The U.S. will now use warning labels and standardized language developed through the United Nations (UN) to communicate hazardous chemical information. On March 26, 2012, U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) published the final rule revising the Hazard Communication Standard (HCS) at 29 Code of Federal Regulations (CFR) 1910.1200. By issuing this final rule, the U.S. will adopt the United Nations’ Globally Harmonized System of Classification and Labelling of Chemicals (GHS).

What are some of the changes to the HCS?

Modifications to the HCS include:

  • Revised criteria for classification of chemical hazards
  • Revised labeling provisions that include requirements for use of standardized signal words, pictograms, relevant hazard statements, and precautionary statements
  • A specified format for safety data sheets (SDS), which now includes 16 sections, covering areas such as substance and hazard identification, first-aid measures, and physical and chemical properties (the term SDS will replace the term MSDS)
  • Related revisions to definitions of terms used in the standard, and requirements for employee training on labels and safety data sheets.

One notable change is the revision of the “unclassified hazards” category, which has been renamed “hazards not otherwise classified.” Employers would identify adverse or physical health effects through evaluation of scientific evidence during the classification process; however, there would likely be very few hazards outside of those covered by specific criteria of the rule.The final standard includes 10 health hazard categories and 16 physical hazard categories.

Health Hazard Categories

  • acute toxicity
  • skin corrosion or irritation
  • serious eye damage or eye irritation
  • respiratory or skin sensitization
  • germ cell mutagenicity
  • carcinogenicity
  • reproductive toxicity
  • specific target organ toxicity through single exposure
  • specific target organ toxicity through repeated exposure
  • aspiration

Physical Hazard Categories

  • explosives
  • flammable gases
  • flammable aerosols
  • oxidizing gases
  • gases under pressure
  • flammable liquids
  • flammable solids
  • self-reactive chemicals
  • pyrophoric liquids
  • pyrophoric solids
  • self-heating chemicals
  • chemicals in contact with water that emit flammable gases
  • oxidizing liquids
  • oxidizing solids
  • organic peroxides
  • corrosive to metals

OSHA is retaining the requirement to include the American Conference of Government Industrial Hygienists (ACGIH) Threshold Limit Values (TLVs) on the SDS in the revised HCS.  OSHA now includes dusts under its definition for hazardous chemicals, requiring that employers account for them on SDSs and in worker training.  OSHA is also modifying provisions of two other standards, including standards for flammable and combustible liquids, process safety management, and most substance-specific health standards, to ensure consistency with the modified HCS requirements.

When does the final rule become effective?

The final rule becomes effective on May 25, 2012, which is 60 days after the publication of the final rule in the federal register (77 FR 17574).

According to the OSHA Fact Sheet for the HCS Final Rule, chemical users and producers should be aware of the following deadlines:

  • Chemical Users:  Continue to update SDS when new ones become available, provide training on the new label elements, and update hazard communication programs if new hazards are identified.
  • Chemical Producers:  Review hazard information for all chemicals produced or imported, classify chemicals according to the new classification criteria, and update labels and safety data sheets.

Effective Completion Date



December 1, 2013

Train employees on the new label elements and SDS format.


June 1, 2015*

December 1, 2015

Comply with all modified provisions of this final rule, except:

Distributors may ship products labeled by manufacturers under the old system until December 1, 2015.

Chemical manufacturers, importers, distributors and employers

June 1, 2016

Update alternative workplace labeling and hazard communication programs as necessary, and provide additional employee training for newly identified physical or health hazards.


Transition Period

Comply with either 29 CFR 1910.1200 (this final standard), or the current standard, or both.

All chemical manufacturers, importers, distributors and employers


* This date coincides with the European Union implementation date for classification of mixtures.

During the phase-in period, employers would be required to be in compliance with either the existing HCS or the revised HCS, or both. From the information available on the OSHA website, OSHA recognizes that hazard communication programs will go through a period of time where labels and SDSs under both standards will be present in the workplace.  This will be considered acceptable, and employers are not required to maintain two sets of labels and SDSs for compliance purposes.

Where can we find more information?

The OSHA FactSheet for HCS Final Rule, in addition to other information and guidance, is available at

To view the HCS final rule in the federal register, go to

The GHS can be reviewed at the United Nations Economic Commission for Europe’s website at

For more information, please contact Amy Bauer at 251-533-6949 and or Tom Biksey at 724-884-6724 and or for more information.




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