The first major overhaul of US chemical safety regulations in over a decade introduces sweeping changes to classification, labeling and documentation requirements. Philip Mole of VelocityEHS maps out the critical updates and compliance deadlines facing manufacturers and downstream users starting next year.
In workplaces where employees may be exposed to hazardous chemicals, the hazard communication standard, or HazCom, is one of the most important regulations US businesses need to follow. It’s also important to remember that meeting HazCom requirements isn’t just a regulatory obligation but an important means to ensure that everyone working for you makes it home safely every day.
That has been true since OSHA unveiled HazCom in 1983, but now, thanks to new requirements that are already in effect on a phased-in compliance timeline, HazCom has become even more effective at supporting workplace safety.
HazCom changes
For more than four decades, HazCom has defined standards and procedures designed to ensure that chemical manufacturers and suppliers classify their chemicals and provide information about chemical hazards to downstream businesses using those chemicals. The ultimate intent is to ensure that any workers exposed to those chemicals have access to information about hazards and understand how to store and work with the chemicals as safely as possible. Over the years, HazCom has undoubtedly saved thousands of lives and prevented tens of thousands of injuries by creating the conditions necessary to reduce exposures of workers to hazardous chemicals.
Although HazCom has long been an effective and important standard for ensuring workplace safety, it was subject to some drawbacks and limitations. One big challenge was inconsistencies in the pictograms chemical manufacturers used on their shipped container labels and a wide variety of ways manufacturers formatted information in material safety data sheets (MSDSs), which made it difficult for end users to identify chemical hazards and quickly find crucial information needed to respond to a spill or chemical exposure.
To address challenges like these, OSHA first aligned HazCom with Revision 3 of the UN’s Globally Harmonized System of Classification and Labeling of Chemicals (GHS) in 2012. Among other changes, this update standardized the format for documents supplied by manufactures (now called safety data sheets, or SDSs) and the pictograms manufacturers could use on their shipped container labels.
While this improved the quality of information supplied by chemical manufacturers and available to end users, the GHS continued evolving, with a UN subcommittee reviewing and updating the GHS every two years. OSHA began planning an update to HazCom to align with a later edition of the GHS in 2018 and proposed an updated version of the HazCom rules in 2021. After accepting and reviewing comments from stakeholders, OSHA finalized the HazCom rule in 2024.
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Read moreDetailsKey updates
The updated HazCom rule mostly aligns with GHS Revision 7 and select elements of Revision 8. HazCom 2024 introduced changes across multiple facets of the standard, including:
- Hazard classes and classifications: The updates change the way HazCom classifies some chemicals (particularly aerosols, desensitized explosives, flammable gases and chemicals under pressure), which changes some of the information manufacturers must provide on the SDSs and shipped container labels for those chemicals. As a result, these changes also affect the precautions and workplace HazCom practices for employers who have the affected chemicals in their workplaces.
- Labeling requirements: Labeling rules have changed, with new allowances and requirements for containers OSHA defines as “small” or “very small” chemical containers.
- Updated classification guidance: The 2024 version of HazCom includes more specific guidance on how manufacturers should classify chemical substances, and the analytical methods they can use.
- Expanded SDS content: Safety data sheets, which register information about chemicals, must now provide additional data, such as “particle characteristics,” in Section 9.
- Classification based on intrinsic hazards: Chemical manufacturers must include information about chemical hazards from known or reasonably anticipated downstream uses of their products in their classification and include the information in Section 2 of the SDS.
While all of the requirements above impact chemical manufacturers, as anticipated, everyone throughout the chemical supply chain who stores and uses hazardous chemicals will have work to do because of HazCom 2024, which is what makes the changes such a big deal for so many businesses.
For example, employers must make sure they receive updated SDS and shipped container labels from their suppliers, and then actually use the information to update their written HazCom plan and training program, such as by accounting for new classifications like chemicals under pressure and desensitized explosives and making sure employees understand how to work safely with them.
Deadlines for meeting the new requirements vary depending on company type:
- Manufacturers of chemical substances must update their processes by Jan. 19, 2026.
- Employers that make use of substances impacted by the final HazCom rule have until July 20, 2026, to comply.
- The deadline for manufacturers of mixtures is July 19, 2027.
- The latest deadline in HazCom final rule implementation, which is for employers that use mixtures (instead of substances in their raw form), is Jan. 19, 2028.
Preparing for the changes
For chemical manufacturers and their customers alike, the updated HazCom final rule has substantial implications, and meeting them will be no easy feat. But the following strategies can help to streamline the process while maintaining the integrity of the workplace safety protections that HazCom helps to enforce.
- Manage the churn of updated SDSs: Because the HazCom update includes changes to chemical classifications and requires new types of data, many businesses will need to update their chemical inventories. Software can help in this task.
- Digitize SDSs: Giving employees access to SDSs in digital form has long been a best practice because it makes it easier for them to locate the critical information they need to remain safe.
Update your workplace HazCom training: Training should begin before employees become active at the worksite, and it should be repeated as HazCom requirements or practices change.
Philip Molé is principal of marketing content at VelocityEHS, an environmental health and safety software provider. Before joining VelocityEHS, he served in various environmental consulting and safety roles. 
