If your business manufactures, imports, distributes, or uses chemicals in the workplace, then you’ll be affected by updates to the Occupational Safety and Health Administration’s (OSHA) Hazard Communication Standard (HazCom). A variety of new requirements will come into effect on specific deadlines between January 19, 2026, and January 19, 2028.
The new HazCom rule updates the standard to align with GHS Rev. 7 and some provisions from GHS Rev. 8. Changes cover a variety of areas, including new and changed hazard classes for Safety Data Sheets (SDSs) and labels, confidential business information, and shipping.
OSHA has enacted these changes to improve the standard’s effectiveness by better-informing employees about chemical hazards in the workplace, increasing worker protection, and reducing chemical-related occupational illnesses and injuries.
The Relationship Between HazCom and GHS Standards
OSHA implemented the original HazCom standard in 1983, further expanding its scope in 1987 to cover all industries where employees faced potential hazardous chemical exposure. This initial iteration of HazCom made use of now outdated Material Safety Data Sheets (MSDSs).
In 2012, OSHA updated HazCom to align with the 3rd revision of the United Nations’ Globally Harmonized System of Classification and Labelling of Chemicals (GHS). The GHS is an international standard used by many countries throughout the world.
On May 20, 2024, OSHA published a new rule that initiates the update of HazCom from GHS Rev. 3 to GHS Rev. 7 and some provisions from GHS Rev. 8. This comes after a similar move by Canada in 2023, which updated the Canadian Hazardous Products Regulations to GHS Rev. 7.
Updated Hazard Classification Requirements
Many of the key changes between GHS Rev. 3 and GHS Rev. 7 focus on hazard classification. Several hazard classes have been updated with new categories, sub-categories, and other criteria.
The change to GHS Rev. 7 updates the flammable gases hazard classification with new sub-categories. It divides Category 1 into sub-categories 1A and 1B. The new sub-categories have different lower flammability limits, along with distinguishing pyrophoric gases and chemically unstable gases.
A change to the flammable aerosols hazard classification renames it to simply “aerosols.” The classification now includes both flammable and non-flammable aerosols, with non-flammable aerosols designated as Category 3.
GHS Rev. 7 also adds a new hazard class, desensitized explosives. It includes explosive substances or mixtures that have been wetted with water or alcohols, diluted with other substances, or dissolved or suspended in water or other substances to suppress or reduce explosive properties. The class features four categories based on the corrected burning rate.
Some changes to HAZCOM originate from GHS Rev. 8. That includes the addition of the chemicals under pressure classification. This new classification includes liquids and solids pressurized with a gas other than those in aerosol containers. This accounts for chemicals that aren’t accurately described by the aerosol or gases under pressure classifications but still pose potential hazards.
HAZCOM has long included combustible dust as a hazard, even though this isn’t a GHS hazard class. The recent update provides a new definition for the combustible dust hazard – “finely divided solid particulates of a substance or mixture that pose a flash-fire hazard or explosion hazard when dispersed in air or other oxidizing media.”
HazCom Requirements and Confidential Business Information
Chemical producers often seek to limit the release of confidential business information (CBI) in safety data sheets (SDSs) and other mandatory documentation. The HAZCOM update changes rules surrounding ingredient concentration disclosure required in section 3 of SDSs, allowing chemical producers to use the following ranges instead of providing exact concentrations.
Chemical Ingredient Concentration Ranges | ||||
(a) 0.1 to 1% | (b) 0.5 to 1.5% | (c) 1 to 5% | (d) 3 to 7% | (e) 5 to 10% |
(f) 7 to 13% | (g) 10 to 30% | (h) 15 to 40% | (i) 30 to 60% | (j) 45 to 70% |
(k) 60 to 80% | (l) 65 to 85% | (m) 80 to 100% |
OSHA Labeling Requirements for Small Containers
New OSHA labeling requirements provide some allowances for small and very small containers. Chemical manufacturers, distributors, and importers now face reduced requirements for labeling very small containers of 3ml or less, only needing to provide a product identifier.
Small containers, defined as those 100ml or less, also face reduced labeling requirements if it is not possible to attach options such as pull-out or fold-back labels. Shipments of these containers must include complete information for each hazardous chemical, although not necessarily as hazard communication labels on individual containers.
Timeline for the Updated Hazard Communication Standard
OSHA announced the new rule on May 20, 2024, with an effective date of July 19, 2024. The rule establishes a transition period with specific timelines for different stakeholders to implement the various changes required by the updated HazCom standard. The table below lays out deadlines for the transition period.
Compliance Date | Requirement(s) | Who |
January 19, 2026 | Update labels and SDSs for substances | Chemical manufacturers, importers, distributors, and employers |
July 19, 2026 | Update workplace labels, hazard communication program, and training for substances | Employers |
July 19, 2027 | Update labels and SDSs for mixtures | Chemical manufacturers, importers, distributors, and employers |
January 19, 2028 | Update workplace labels, hazard communication program, and training for mixtures | Employers |
During the transition period between July 19, 2024, and each of the effective completion dates above, stakeholders may choose to comply with the updated HazCom standard, the previous 2012 HazCom standard, or both.
Maintaining HazCom Compliance With ERA
Chemical manufacturers, importers, distributors, and employers whose workplaces include hazardous chemicals must now update their SDSs, labels, other documentation, and training programs to align with the new HazCom standard. Doing so is essential both to avoid potential fines and penalties and to ensure safe workplaces and transportation.
ERA provides both enterprise SDS Authoring software and scalable SDS on Demand solutions for organizations of any size. You can rest easy knowing that your SDSs, labels, and other documentation are backed by ongoing chemical data and regulatory updates from ERA’s expert researchers. You’ll also save your team time and money with a streamlined SDS authoring process that lets you create complete documents under HazCom, GHS, and other standards.
Schedule a discovery call with one of our project analysts to find out more about how ERA’s SDS software solutions can keep your organization compliant with current and future regulatory requirements.
Contributing Scientist of This Article:

January 20, 2025
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