Understanding OSHA’s Hazard Communication (HazCom) Standard and its alignment with the Globally Harmonized System (GHS) is crucial for businesses handling hazardous chemicals, especially because the compliance timeline for OSHA’s 2024 HazCom final rule has already started. The final rule aligns HazCom with Revision 7 (and select elements of Revision 8) of the GHS, and it affects all users of hazardous chemicals throughout the supply chain. If you haven’t already started updating your chemical management practices to meet updated requirements, you’re already behind.
The following summary is based on our recent HazCom webinar on the 2024 HazCom final rule. It provides the details you need to get started or make sure your current efforts are on track.
Background of HazCom
Established in 1983 (and initially applicable only to a small subset of companies), the HazCom Standard ensures effective communication of chemical hazards to workers. It has evolved to encompass all industries and align with international standards, such as the GHS, which happened when OSHA issued a final rule in 2012 to revise HazCom based on GHS Revision 3.
HazCom 2012 had a transition period that ended between 2016 and 2017 and resulted in the adoption of the GHS’s standardized format for safety data sheets (SDSs) and shipped container labeling information. But in the years since, the UN continued to update the GHS every 2 years, resulting in HazCom 2012 becoming out of phase with current recognized global best practices. OSHA first proposed updating HazCom to align with more recent editions of the GHS in 2021 and finally issued a final rule in 2024 that is now already in effect.
Key Updates in the 2024 HazCom Final Rule
The final rule issued in May 2024 introduces significant changes to HazCom. Here are some of the key updates:
Hazard Classifications
HazCom 2024 expands the aerosols hazard class to include non-flammable aerosols, now categorized under a new Category 3. This adjustment aims to enhance user understanding of the specific hazards associated with various aerosols, and the ways that container failure mechanisms differ from those of gases under pressure (aka, gas cylinders), the category that many aerosols previously found themselves in.
The rule also adds a category for chemicals under pressure, following and adopting the categories of chemicals under pressure from GHS Revision 8. The new classification includes liquids or solids pressurized with gas, which improves hazard communication clarity.
Another critical update is the addition of desensitized explosives as a new hazard class. These products, stabilized with a wetting or stabilizing agent, are safer to handle than ordinary explosives as long as the stabilizing agent is in place and effective. The classification system now includes four categories based on corrected burning rates, offering detailed stability and hazard information to users, including how to confirm that stabilizing agents are in place.
The final rule also modifies the classification of flammable gases, splitting Category 1 into subcategories 1A and 1B, better distinguishing hazards associated with different flammable gases. Pyrophoric and chemically unstable gases fall under Category 1A, emphasizing the need for specific hazard and precautionary statements for safe handling.
Labeling Requirement Changes
HazCom 2024 introduces new allowances for small and very small containers. For small containers (up to 100 milliliters), manufacturers can use abbreviated label information if the full shipped container label information is on the outer packaging.
For very small containers (up to 3 milliliters), only the product identifier is required on the container, if the manufacturer argues that a label would interfere with the normal use of the container. Once again, a chemical manufacturer who takes advantage of this allowance would need to provide full shipped container full label information on the outer packaging.
Both manufacturers of small and very small containers also need to include a statement on the outer packaging telling users to replace the small and very small containers in the outer packaging when the containers are not in use.
These allowances and requirements balance the need for hazard communication with practical labeling considerations, ensuring essential safety information remains accessible.
Chemicals Released for Shipment
A significant update to the HazCom Standard relieves chemical manufacturers of the need to relabel “chemicals released for shipment” if they learn of new hazard information, although they still would need to provide an updated shipped container label with the shipment.
This change reflects OSHA’s consideration of the lengthy distribution cycles for some products, which can lead to extended warehouse storage. Previously, new hazard information required relabeling, posing risks during the process, since employees would need to access containers that may already have been bundled and palletized.
Other Updates Under HazCom 2024
Bulk Shipments
A significant update pertains to the classification and labeling of bulk shipments. OSHA has clarified that a bulk shipment refers to any hazardous chemical transported in a container that also serves as the mode of transportation, such as tanker trucks or railcars. This update aligns with a 2016 joint memorandum with the Department of Transportation (DOT), allowing the same container to display both OSHA HazCom and DOT labels. This dual labeling ensures effective communication of all necessary hazard information, enhancing safety and compliance across different transportation methods.
Hazard and Precautionary Statements
Additionally, the final rule introduces changes to hazard and precautionary statements, aligning them more closely with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) Revision 7. HazCom 2024 now permits minor textual variations to avoid redundancy, acknowledging the limited space on labels.
Trade Secrets and Confidential Business Information (CBI) Claims
OSHA has also expanded trade secret provisions, enabling manufacturers to withhold concentration ranges as trade secrets, provided they choose from a prescribed list. This adjustment aligns better with Canadian regulations and offers manufacturers greater flexibility while maintaining transparency and safety. Previously, OSHA only allowed chemical manufacturers to withhold the specific concentration as CBI.
Intrinsic Hazards and Downstream Uses of Chemicals
HazCom 2024 requires chemical manufacturers to consider intrinsic hazards in chemical classifications, including those related to chemical reactions or changes in form from known or reasonably anticipated downstream uses of the chemical, and to include that information in Section 2 of the SDS. This ensures that end users receive detailed and accurate hazard information, facilitating safe handling of chemicals.
Key Takeaways on the 2024 HazCom Final Rule
The updates to OSHA’s HazCom Standard reflect an ongoing commitment by OSHA to align with international best practices and enhance workplace safety. By introducing new hazard categories, refining classification systems, and allowing practical labeling, OSHA ensures that workers have access to clear and accurate chemical information.
Businesses must make sure they understand these changes and adjust their hazard communication practices to maintain compliance and safeguard their employees. This final rule marks a significant advancement in chemical safety, emphasizing the importance of effective hazard communication in today’s regulatory environment.
For more information about HazCom 2024, check out our entire on-demand webinar.
Let VelocityEHS Help!
There’s never been a more urgent time to make sure your chemical and SDS management practices are working effectively. The VelocityEHS Chemical Management Solution makes it easy for you to maintain an updated SDS library that you and your people can access from anywhere 24/7. With our software, you’ll be better able to keep your SDS library up to date as your chemical manufacturers reauthor SDSs in alignment with HazCom 2024, and you’ll be better positioned to use the updated information to revise your workplace HazCom management practices.
You’ll also get deeper insights into your chemical inventory with support for chemical ingredient indexing so you can extract information on chemical ingredients from SDSs and cross-reference them against various regulatory lists such as EPA’s Extremely Hazardous Substances (EHSs) and Toxic Release Inventory (TRI) reportable chemicals. The software provides a Levels of Concern (LoC) summary containing regulatory radar screen “hits” and other key information, including established Occupational Exposure Limits (OELs) you need to know when managing your indoor air sampling program.
Best of all, Chemical Management is only one of the solutions on our Accelerate® Platform. It also includes Industrial Ergonomics, Safety, and Operational Risk, all of which are then available via a single sign-on, providing you with an integrated user experience and unified reporting capabilities across all four solutions.
Contact us today to learn more about our solutions and services and the ways we can help you maintain compliance with HazCom or schedule a demo.