The Occupational Safety and Health Administration (OSHA) Hazard Communication Standard (HCS) final rule was published on May 20, 2024, in the Federal Register. This OSHA 2024 update amends the HCS to conform to the United Nations’ Globally Harmonized System of Classification and Labelling of Chemicals (GHS). The 2024 HCS final rule intends to enhance worker safety through better communication on chemical hazards.
Since its inception in 1983, the HCS has provided comprehensive information on workplace chemicals, but it allowed flexibility in label and safety data sheet formats. While this flexibility has been beneficial, a standardized approach offered by the GHS will be more effective. The GHS includes specific criteria for classifying hazards and standardized label elements, improving understanding and safe handling of chemicals.
What You Need to Know
The new Hazard Communication Standard mandates a consistent format for safety data sheets, making information more accessible for employers, workers, health professionals, and emergency responders.
This standardized approach will also harmonize communication with international partners, reducing confusion from varying national and international requirements. Adoption of the GHS globally will ensure that chemicals crossing borders have consistent, clear hazard information, improving global safety and communication.
Key Updates to the HCS
The OSHA HCS will take effect on July 19, 2024. The revisions aim to improve the standard’s effectiveness by providing more information to workers and first responders about chemical hazards in the workplace. In addition, the HCS update also addresses issues that arose during the implementation of the 2012 standard and aims to align with other federal agencies and international trading partners.
The 2024 HCS updates include:
• Labeling requirements for small packaging have been updated to ensure labels are comprehensive and readable. Labels must be legible, in English, and prominently displayed, but other languages may also be used.
• A new hazard class, desensitized explosives, has been added, as well as new hazard categories for chemicals under pressure within aerosols and unstable gases in flammable gases.
• New definitions have been added for bulk shipment, combustible dust, gas, liquid, solid, immediate outer package, physician, or other licensed health-care professional (PLHCP) and released for shipment.
• Rules for trade secrets on SDS have been revised. Manufacturers will be required to disclose the concentration range in which a secret concentration falls, using a specified list of narrow ranges currently used by Health Canada.
• Employers will have the option not to relabel chemicals released for shipment if new hazards are identified, but they will need to provide an updated label with the shipment.
The revised Hazard Communication Standard (HCS) mandates that workers be retrained within two years of the final rule’s publication to ensure they can recognize and understand the new labels and safety data sheets.
Hazard Communication Standard Training
HCS has always been intended to ensure that employees understand how to take the appropriate precautions and use protective measures to avoid chemical exposure and workplace injuries. The requirements for HCS training are outlined in OSHA regulation 29 CFR 1910.1200(h).
How to Make Hazard Communication Standard Training More Valuable
Here are some of the things I use to keep HCS interesting and relevant:
• Incorporate quizzes, interactive modules, and hands-on activities.
• Use real-life scenarios to demonstrate the importance of HCS training.
• Create visually appealing Safety Data Sheets (SDSs) and labels.
• Share case studies of chemical incidents in similar workplaces.
• Discuss lessons learned from past accidents and near-misses.
• Conduct live demonstrations of proper handling and storage of chemicals.
• Show the correct use of personal protective equipment (PPE).
• Offer refresher courses to keep information current and top-of-mind.
• Encourage employees to share their experiences and best practices.
• Gather feedback from employees about the training process.
• Ask for training feedback and adjust the training program based on their suggestions and needs.
• Ensure easy access to SDSs and other safety resources.
• Provide digital tools and apps for quick reference and learning on-the-go.
Hands-On Learning is Key
It is important to make HCS training relevant to the work while doing their job. Many companies use online HCS training that covers the general aspects required by the HCS standard but fails
to show the employee how it directly applies to the chemicals and handling procedures in their everyday work.
Make sure you do what’s right for your employees and implement hands-on learning, in-person coaching, and skills checks.
This knowledge not only helps in maintaining a safe work environment but also ensures compliance with OSHA regulations, reducing the risk of chemical-related incidents and promoting a culture of safety.