Significant Updates to OSHA’s HazComm Standard Forthcoming

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The long awaited update to the U.S. Occupational Safety and Health Administration (OSHA) Hazard Communication Standard (HCS) is on its way.  OSHA has published an advance copy of its Notice of Proposed Rulemaking which is scheduled to be published in the Federal Register on Tuesday, February 16, 2021.  Appropriate comments on this NPRM will be accepted by OSHA until April 19, 2021.

The proposed rule was initially drafted in 2019 but publication was put on hold until it was finally released by the new administration.  The Hazard Communication Standard (HCS) was last updated in 2012.  The update is based on the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS) and is intended to align OSHA’s Hazard Communication Standard (HCS) with other federal agencies and international standards.

OSHA reported that the proposed changes would improve hazard communication and “…will reduce costs and burdens while also improving the quality and consistency of information provided to employers and employees regarding chemical hazards and associated protective measures.”

Most notably, the proposed rule will bring the United States closer to international harmonization with respect to chemical hazard communication.  Previously, US OSHA recognized Revision 3 of the GHS.  This proposed rule will advance the US by 8 years (4 revisions) and recognize Revision 7.  One of the most significant impacts will be the recognition of non-flammable aerosols (GHS Aerosols Category 3).  Previously, non-flammable aerosols were only recognized as Gases Under Pressure (compressed) and required the cylinder pictogram.  Under this proposed rule, non-flammable aerosols will be recognized as Aerosols 3 and not require a pictogram.

Also incorporated into this NPRM are provisions for desensitized explosives; a new hazard category for pyrophoric gases; miscellaneous provisions intended to clarify the criteria for some hazard classes (explosives, specific target organ toxicity following single exposure, aspiration hazard, and hazardous to the aquatic environment); additional information to be included in section 9 of the SDS; revised precautionary statements; and a new example in Annex 7 addressing labelling of small packages – all changes consistent with GHS Revision 6. 

Additional changes from Revision 7 (2017) will include revised criteria for categorization of flammable gases within Category 1; miscellaneous amendments intended to clarify the definitions of some health hazard classes; additional guidance regarding the coverage of section 14 of the SDS (which is non-mandatory under the HCS); and a new example in Annex 7 addressing labelling of small packages with foldout label. 

OSHA is proposing to revise the HCS to align with the GHS Revision 7; however, the agency has included select provisions from Revision 8 for consideration in this rulemaking.

Revision 8 (published July 2019) includes a change in classification criteria for aerosols (based on flammable properties, heat of combustion); minor changes to precautionary statements for skin irritation and serious eye damage; new provisions for use of non-animal test methods for the skin irritation/corrosion hazard class; and new precautionary pictograms for “keep out of reach of children.”

OSHA is proposing “…substantial revisions to appendix A.2 (skin corrosion/irritation) that reflect changes the UN subcommittee adopted through the GHS Revision 7.  However, the GHS Revision 8, published in July 2019, expanded the use of non-animal test methods in Chapter 3.2 (skin corrosion/irritation).  These changes include recognition of specific in vitro test methods, reorganization of the chapter, reorganization of the tiered approach to reflect those changes, as well as descriptive text on use of new test methods, structure activity relationship (SAR) and read across methods, and an updated decision logic diagram.

The expansion of non-animal test methods for use in hazard classification could potentially result in cost savings, as hazard testing for new chemicals could be done using potentially cheaper (non-animal) test methods.  If OSHA were to adopt these changes, they would be reflected in appendix A.2 Skin Corrosion/Irritation.”

For more information about the proposed rule, contact the author, Steve Hunt, ShipMate, Inc. at (Tel: +1 (310) 370-3600 or e-mail or click on the following link:

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