OSHA’s Updated HCS (HAZCOM) Standard: What Do You Need to Know?

The Occupational Safety and Health Administration (OSHA) of the United States Department of Labor first published the Hazard Communication Standard (HCS or HAZCOM Standard) [29 CFR 1910.1200] in 1983, which required those who produce or import chemicals to assess the hazards of their products. This included provisions for proper container labeling and required dissemination of chemical-specific Material Safety Data Sheets (MSDSs) to all workers potentially exposed to a given chemical. MSDSs were later replaced by the globally standardized Safety Data Sheets, or SDSs, which shall be discussed in more detail below. HCS was not limited to a finite list of chemicals but rather any chemical used in an American workplace.

Throughout the years, there have been various amendments to HCS, perhaps most notably concerning the quality control surrounding MSDSs. Ultimately, in 2015, the HCS was revised to require manufacturers to provide SDSs for any chemicals sold. SDSs are similar to MSDSs. However, they are fully conforming to Global Harmonized System (GHS) Standards, prepared in the required 16-section format. On May 20, 2024, the latest revision to the HCS was published with the intention of better unifying OSHA Standards with that of GHS, aligning with the standards of international agencies and trading partners. The final rule shall be effective on July 19, 2024.

What are the most notable changes to HCS with the 2024 revisions?

• 29 CFR 1910.6 was updated to include additional national and international consensus standards
• New definitions for terms like bulk shipment, combustible dust, immediate outer package, and released for shipment are included
• Chemical manufacturers and importers must include any hazards related to the intrinsic properties of a chemical (change in physical form/chemical reaction products with anticipated uses)
• A United States address and phone number must be included on labels for shipped containers
• Bulk shipments of hazardous chemicals must have labels on each immediate container
• Containers that are categorized as “small containers” (<100 mL, <3 mL) are allowed to contain labels with relatively limited information when compared to standard-sized containers
• Increased requirements for providing more specific concentrations of chemicals that are claimed as a trade secret

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