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3 Changes to OSHA’s Hazard Communication Standard You Need to Know About

February 17, 2015

History of the Hazard Communication Standard (HCS)

The Occupation Health and Safety Administration (OSHA) first promulgated the Hazard Communication Standard (HCS), or “HazCom Standard” for short, on November 25th, 1983.

The HCS (also known as the “Right-to-Know Law”) was designed to help inform employers and employees of the hazardous nature of chemicals used or stored in the workplace. The standard also applies to chemical manufacturers.

The HCS was later broadened in scope to include all industries in which there might be a potential for employee chemical exposure, and went into effect on March 11th, 1994.

The standard allowed all employees unfettered access to Material Safety Data Sheets (MSDS), the proper training for directly handling toxic chemicals, and information on the detection and prevention of chemical releases.

But a lack of uniformity of the HCS with global chemical hazard standards caused problems, especially in the transnational shipment of hazardous chemicals.

So on March 26th, 2012, OSHA, with participation from the Environmental Protection Agency (EPA), the Department of Transportation (DOT), and Consumer Product Safety Commission, published the Hazard Communication Standard Final Rule in the Federal Register.

Related Article: OSHA 2015 Regulatory Changes: Will You Be Ready?

Hazard Communication Standard (HCS) GHS Pictogram

An Example of a Pictogram From the New Hazard Communication Standard (HCS)

2012 HCS Final Rule: From the “Right-to-Know” to the “Right-to-Understand”

Prior to the proposed changes, the HCS was a “performance-based” system of chemical labeling and information comprised of six major categories, including:

  • Hazard Determination,
  • Safety Data Sheets,
  • Labels and other Forms of Warning,
  • Employee Information and Training,
  • The Written Hazard Communication Programand
  • Trade Secrets.

The 2012 revisions to the HCS were made in order to align the standard with the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS).

By conforming to this international system, OSHA maintains that the uniformity and comprehensiveness of the HCS is improved—making the standard easier to understand.

A reduction in occupational illnesses and fatalities, improvements in trade conditions, and increased international intelligibility—in both the language and formatting of hazard information—were also motivating factors behind the unification of the HCS with the GHS.

OSHA has estimated that over 43 million workers in more than 5 million workplaces across the nation will be affected by the new revisions to the HazCom standard.

The three main areas affected by the Final Rule are hazard classification, labels and safety data sheets (SDS).

The Final Rule’s Three Areas of Change

Hazard Classification

The criteria for what constitute a hazard and the classification of mixtures have been changed to ensure that the evaluations of hazardous effects of chemicals are uniform across all manufacturers and so that the resulting labels and safety data sheets are also more accurate and consistent.

Among the new additions is the definition of “hazards not otherwise classified”. “Hazards not otherwise classified (HNOC)” ensure that all adverse health effects that do not meet the specific criteria of a hazard class are addressed and covered by the standard.

Another addition is the categorization of hazards within a hazard class and the determination of the severity of these hazards rather than defining the effect itself, such as carcinogenicity.


Chemical manufacturers and importers must provide labels that include GHS-harmonized pictograms, signal words, and hazard statements for each class and category of hazard. Precautionary statements are also required under new revisions.

A pictogram is a composition that includes a symbol with other graphic elements, like backgrounds, borders, and colors meant to pronounce particular information about the hazardous nature of a chemical. Pictograms must not be blank, and must have red borders are required on shipped containers.

A signal word is a word used to alert the reader of a potential hazard on the label and to convey the level of severity of hazard. Signal words, such as “warning” and “danger”, are used for less severe and more severe hazards, respectively.

A hazard statement is a declaration assigned to a specific hazard class and category that describes the nature of the hazard(s) of a chemical, and also the degree to which it is hazardous. For example: Harmful if inhaled.

[for Category 4 Acute Toxicity – Inhalation].

A precautionary statement is a statement that describes the recommended actions to be taken in order to minimize or prevent the adverse effects of exposure to, or improper storage or handling of, a hazardous chemical. An example of a precautionary statement according to OSHA: Wear face protection [for Explosives, Division 1.1].

Safety Data Sheets (SDS)

Safety data sheets are expanded to a 16-section format comprised of mandatory and non-mandatory categories. According to OSHA, the new SDS format is enumerated in following sixteen sections:

  1. Identification of the substance or mixture and of the supplier
  2. Hazards identification
  3. Composition/information on ingredients
  4. First-aid measures
  5. Fire-fighting measures
  6. Accidental release measures
  7. Handling and storage
  8. Exposure controls/personal protection.
  9. Physical and chemical properties
  10. Stability and reactivity
  11. Toxicological information
  12. Ecological information (non-mandatory)
  13. Disposal considerations (non-mandatory)
  14. Transport information (non-mandatory)
  15. Regulatory information (non-mandatory)
  16. Other information, including date of preparation or last revision

Effective Dates of the HCS Final Rule

Although the HSC Final Rule was first proposed nearly three years ago, OSHA has given employers and employees time to adhere to the new standards. The final rule must followed according to the dates in the table below, provided by OSHA.

Effective Completion DateRequirement(s)Who
June 1, 2015*December 1, 2015Comply 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, 2016Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards.Employers
Transition PeriodComply 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.

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Sources: OSHA Fact Sheet: Hazard Communication Standard Final Rule

AIHA – OSHA 2012 New Hazard Communication Standard.pdf

Photo credit: Wikimedia Commons

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