Stay up-to-date on proposed changes to OSHA hazard communication standards

OSHA.gov

OSHA published a notice of proposed rulemaking (NPRM) in February 2021 on updating the hazard communication standard to align with Revision Seven of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). OSHA has been planning on updating this “HazCom” standard since 2018, yet their efforts have been delayed until recently. Since the public can finally see the proposed changes, we can begin to estimate the impacts the new standards will have.

It is important to remember these rule changes are only in the proposal stage, so only time will tell which standards will and will not end up being adopted. With that in mind, here is a quick summary of these proposed standards.

New proposed classifications:

• Aerosols – Non-flammable aerosols will now be under a newly-created category three, while flammable aerosols will be categories one and two. OSHA realized the current classification doesn’t fully represent the full spectrum of varying aerosol hazards.
• Desensitized explosives – Proposed adding of a new fourth category for desensitized explosives. Hazard training should cover desensitized explosives and what makes them explosive.
• Flammable gas – Proposed subdivide of category one into two sub-categories (1a and 1b). Mainly so there aren’t distinctions between gasses with a wide range of flammable properties.

Other proposed revisions:

• New labeling provisions for “small” and “very small” containers.
• Updates to select hazard and precautionary statements for more precise information.
• Updates to labeling requirements for packaging containers “released for shipment.”
• Labels for bulk shipments of hazardous chemicals.
• Inclusion of trade secrets on Safety Data Sheets.
• Updates to Safety Data Sheet section two – hazard identification.
• Potential changes associated with revision eight.

To wrap up the biggest takeaways, this NPRM is possibly the first significant update to the HazCom standard since 2012. This hits the distributors and manufactures of the hazardous chemicals the hardest. They will most likely have to re-evaluate the standards on products they sell or import and make necessary adjustments. Many safety data sheets and labels will need to be re-authorized to reflect the possible new classifications to ensure compliance. Again, these standards are in the process of being finalized, so make sure to stay updated on which changes are adopted and how they will affect your workplace moving forward.

Submitted by:  Michael Neff, Loss Control Consultant