Major Changes to the Hazard Communication Standard
Posted: Tue Dec 17, 2024 6:10 am
Incorporation by Reference : The general incorporation by reference section, 29 CFR 1910.6 OSHA HCS, has been updated to include more recent national and international consensus standards. OSHA does not intend to require reclassification of chemicals already classified using an earlier version of a consensus standard.
8 New Definitions : Bulk packaging, combustible dust, gas, liquid, solid, immediate outer package, physician or other licensed healthcare professional (PLHCP), and released for shipment were added as defined terms.
Scope and Application, and Clarification of Amendment : The Scope and Application investor database section of the HCS identifies the chemicals that are (and are not) covered by the revised Hazard Communication Standard. In the Hazard Classification section, OSHA revised this section to clarify the distinction between hazards associated with the chemical and hazards associated with downstream uses (e.g., chemical reactions). This change was made to align the scope language with OSHA’s longstanding position that the HCS covers chemicals under normal conditions of use and foreseeable emergencies.
Hazard Classification (Appendix A and B) : The health and physical hazards covered by the HCS update and addressed in Appendices A and B include classification criteria consistent with the GHS. The following table summarizes the health and physical hazard classifications:
OSHA Blog Graphic
The Summary of Changes to Health and Physical Hazard Classification HCS table includes hazard category updates to GHS Rev. 7, updated definitions, and additional changes.
Allocation of Elements (Appendix C ): Alignment with GHS Rev. 7 includes:
a. Guidance to specify the type of equipment where appropriate including hearing equipment.
b. Editorial changes made to improve clarity, correct simple word or phrase omissions, and combine precautionary statements more effectively and concisely.
c. Specific storage changes for multiple hazards.
d. The pyrophoric gas hazard class was removed from OSHA’s Defined Hazards and the hazard was incorporated into the flammable gas hazard class.
e. OSHA is not adopting any statements or instructions regarding consumer products.
Safety Data Sheets (Appendix D) : By adding clarification to Sections 1, 2, 3, 8, 9, 10, 11, and 14, common concerns that were explained in recent Letters of Interpretation (LOI) and aligned with GHS Rev. 7 are addressed. These revisions were made to reduce future confusion and improve overall safety for SDS users.
8 New Definitions : Bulk packaging, combustible dust, gas, liquid, solid, immediate outer package, physician or other licensed healthcare professional (PLHCP), and released for shipment were added as defined terms.
Scope and Application, and Clarification of Amendment : The Scope and Application investor database section of the HCS identifies the chemicals that are (and are not) covered by the revised Hazard Communication Standard. In the Hazard Classification section, OSHA revised this section to clarify the distinction between hazards associated with the chemical and hazards associated with downstream uses (e.g., chemical reactions). This change was made to align the scope language with OSHA’s longstanding position that the HCS covers chemicals under normal conditions of use and foreseeable emergencies.
Hazard Classification (Appendix A and B) : The health and physical hazards covered by the HCS update and addressed in Appendices A and B include classification criteria consistent with the GHS. The following table summarizes the health and physical hazard classifications:
OSHA Blog Graphic
The Summary of Changes to Health and Physical Hazard Classification HCS table includes hazard category updates to GHS Rev. 7, updated definitions, and additional changes.
Allocation of Elements (Appendix C ): Alignment with GHS Rev. 7 includes:
a. Guidance to specify the type of equipment where appropriate including hearing equipment.
b. Editorial changes made to improve clarity, correct simple word or phrase omissions, and combine precautionary statements more effectively and concisely.
c. Specific storage changes for multiple hazards.
d. The pyrophoric gas hazard class was removed from OSHA’s Defined Hazards and the hazard was incorporated into the flammable gas hazard class.
e. OSHA is not adopting any statements or instructions regarding consumer products.
Safety Data Sheets (Appendix D) : By adding clarification to Sections 1, 2, 3, 8, 9, 10, 11, and 14, common concerns that were explained in recent Letters of Interpretation (LOI) and aligned with GHS Rev. 7 are addressed. These revisions were made to reduce future confusion and improve overall safety for SDS users.