Final Hazard Communication Rule: What Do I Need to Know?

The Occupational Safety and Health Administration (OSHA) has issued a final rule that updates the Hazard Communication Standard (HCS) 29 CFR 1910.1200 to align primarily with the seventh revision of the United Nations’ Globally Harmonized System of Classification and Labelling of Chemicals (GHS). The final rule was published on May 20, 2024, and takes effect on July 19, 2024, over three years after it was proposed.

The HCS, also known as HAZCOM, was last updated in 2012 to align with GHS Revision 3. GHS is an international approach to hazard communication that provides harmonized definitions of hazards, specific criteria for labels, and a 16-section format for safety data sheets (SDS).

Major Changes

The rule also incorporates several letters of interpretation OSHA issued since the Hazard Communication rule was last updated. An overview of the major changes include:

• New definitions for bulk shipment, combustible dust, gas, immediate outer package, liquid, physician or other license health care professional (PLHCP), released for shipment, and solid
• Revised definitions for exposure or exposed, hazardous chemical, and physical hazard, including any combinations and reactions it could have with other chemicals as an end product.
• Labeling requirements for certain very small containers and bulk containers
• Significant changes to the flammable gas hazard class
  • These include the addition of a new hazard class (desensitized explosives) and several new hazard categories (unstable gases and pyrophoric gases in the Flammable Gases class and nonflammable aerosols in the Aerosols class)
• Revised health hazard statements and precautionary statements in some cases
  • Revised health hazard definitions, updated Skin corrosion/irritation and Serious eye damage/eye irritation chapters, general updates to hazard classes

Compliance Deadlines

There are 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 (July 20, 2026, for substances and January 19, 2028, for mixtures) to update any alternative workplace labeling, update their Hazard Communication program, and provide any additional employee training for newly identified physical, health, or other hazards in the workplace.

Until those dates, employers and chemical manufacturers, distributors, and importers can comply with either the old or new standard – or both – during the transition period.

How Can ALL4 Help with Hazard Communication?

ALL4 has a team of experts familiar with all aspects of Hazard Communication, health and safety compliance, and management. ALL4 provides regulatory guidance, training, written procedures, compliance evaluations, and more to help with your regulatory needs. If you have questions on the HCS final rule reach out to Victoria Sparks at vsparks@all4inc.com or 859-447-9156.