On May 20, 2024, OSHA published a revised Final Rule for Hazard Communication. Although the rule takes effect on July 19, 2024, several provisions have compliance dates that occur much later, as shown in the table below. OSHA believes this update to the HCS will improve worker protections by clarifying existing regulatory requirements, incorporating new hazard classes and categories, and improving and streamlining precautionary statements.
Most of the changes affect manufacturers and distributors, who now have an increased burden with regard to classifying hazardous chemicals. Manufacturers and distributors will now need to include SDSs in the first shipment of a product and again if there are any changes made to the SDS. They can also tell purchasers where to find SDSs if they are maintained electronically.
One of the significant changes that will affect employers is that very small containers (less than or equal to 100ml capacity) that are too small for GHS labels must carry labels with the following at a minimum, and must remain/be stored inside immediate outer packaging that has the full GHS label:
• Product identifier;
• Pictogram(s);
• Signal word;
• Chemical manufacturer’s name and phone number; and
• A statement that the full label information for the hazardous chemical is provided on the immediate outer package.
Next month’s issue of the Advisor® will include another article detailing further information on changes within the final rule. See table below for compliance date requirements.
| Compliance Date | Requirement(s) | Who |
| 18 months after publication | Update labels and SDSs for substances | Chemical manufacturers, importers, distributors and employers |
| 24 months after publication date | Update workplace labels, hazard communication program and training as necessary | Employers |
| 36 months after publication date | Update labels and SDSs for mixtures | Chemical manufacturers, importers, distributors and employers |
| 42 months after publication date | Update workplace labels, hazard communication program and training as necessary | Employers |
| Transition Period – July 19, 2024 to above-noted compliance dates | May comply with either 29 CFR 1910.1200 (this final standard), or the previous (2012) standard, or both | Chemical manufacturers, importers, distributors, and employers |
