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A long-awaited revision to a U.S. Department of Labor (DOL) rule will be published 20 May 2024, 3E has learned. 3E will provide additional reporting and analysis on the new Occupational Health and Safety Administration (OSHA) Hazard Communication Standard (HCS) as more information becomes available.

OSHA's HCS has been updated to align with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS), Revision 7.

The updated HCS provisions will become effective 60 days after the date of publication of the final rule.

“The hotly contested change to require that hazards associated with a change in physical form and result of chemical reactions as requiring classification was retained in the final rule,” said Terry Wells, 3E's Senior Manager of Regulatory Research for North America. “This was a point of contention with some in industry saying there was not enough guidance and it departs from GHS requirements.”

Review

The HCS was established in 1983 and last underwent a major revision in 2012 to align with GHS Revision 3.

As previously reported by 3E, HazCom and supply chain experts have expected some key elements of the new HCS, including new labeling requirements for small containers and packaged containers that have been released for shipment​​.

The changes are expected to result in a savings of $26.8 million in net savings per year, according to preliminary economic analysis by DOL and OSHA.

Analysis

According to an email sent to members of the Society for Chemical Hazard Communication (SCHC) obtained by 3E, OSHA has established separate dates for substances and mixtures.

Safety data sheet (SDS) authors will be required to submit their SDSs for substances by 19 January 2026 and for mixtures by 19 July 2027.

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About the author: Stefan Modrich is a Washington, D.C.-based reporter for 3E. He covers the latest developments in environmental health and safety policy and regulation. Modrich previously wrote for S&P Global Market Intelligence, The Arizona Republic, and Chicago Tribune. He is an alumnus of Arizona State University and the University of Zagreb.

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