On May 20, 2024, OSHA published finalized revisions to the Hazard Communication Standard (the “HazCom standard”). The HazCom standard is a commonly cited standard in OSHA inspections. The revisions to the rule address the amount and quality of information on labels and SDS and increase access to important hazard information for workers and first responders.

Several notable revisions to the HazCom standard include:

  • Updating the labeling requirements for small packaging to ensure labels are comprehensive and readable;
  • Clarifying the hazard classification process for certain health and physical hazards to provide more accurate information on labels and SDS;
  • Adding requirements to classify chemical hazard types by their “reasonably anticipated” downstream uses;
  • Updating the physical hazard classes to better instruct users on the safe handling of explosives, aerosols and chemicals under pressure;
  • Updating the precautionary statements on how to safely handle, store and dispose of hazardous chemicals;
  • Ensuring that trade secrets protections no longer prevent workers and first responders from quickly accessing critical hazard information on SDS as a reference for first aid, personal protective equipment, and emergency protocols;
  • Adding new definitions for the terms “bulk shipment,” “combustible dust,” “gas,” “immediate outer package,” “liquid,” “physician or other licensed healthcare professional (PLHCP),” “released for shipment,” and “solid;”
  • Revising definitions for “exposure” and “exposed,” “hazardous chemical,” and “physical hazard.”

The newly revised HazCom standard is expected to take effect in July of 2024, with staggered compliance dates for chemical manufacturers, importers, and distributors evaluating substances (January 19, 2026), and mixtures (July 19, 2027).  Employers have six months beyond those dates to update their HazCom program for compliance with this rule  (July 20, 2026 for substances; January 19, 2028, for mixtures). Please contact a Husch Blackwell Safety and Health attorney with any questions about this new development.