OSHA Issues Proposed Rule to Update Hazard Communication Standard

Proposed Hazardous Chemical Label Changes

On February 5, 2021, the U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) issued a proposed rule to update the agency’s Hazard Communication Standard (HCS) to align with the seventh revision of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS).

The HCS, which was established in 1983, initiated the standardization of the approach to workplace hazard communication. Since its inception, OSHA has known the HCS would require periodic updates to maintain consistency and incorporate the progression of scientific principles and best approaches for workplace hazards related to hazardous chemical exposure.

In 1987, OSHA updated the HCS to expand coverage to all industries where workers are exposed to hazardous chemicals. In 1994, OSHA made technical changes and amendments designed to ensure better comprehension and greater compliance with the standard and saw the benefit of an internationally harmonized chemical hazard communication standard. A decade later 2012, the agency officially harmonized the HCS with the third revision of the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS).

Now, OSHA has preliminarily determined that the proposed amendments to the HCS would enhance the effectiveness of the standard by ensuring that employees are appropriately trained on the chemical hazards to which they may be exposed. The proposed changes to the standard include revised:

  • Criteria for classification of certain health and physical hazards

  • Provisions for updating labels

  • Technical amendments related to the contents of Safety Data Sheets

New provisions related to:

  • Chemical concentrations and or concentration ranges being claimed as trade secrets

  • Labeling small containers

Proposed changes will also address issues that have arisen since the implementation of the 2012 GHS update and improve alignment with other federal agencies and Canada.

Individuals may submit comments under Docket No. OSHA-2019-0001, electronically at Federal Register :: Hazard Communication Standard no later than April 19, 2021.


Please contact Christine Silverman or Travis Wheeler if you have any questions or would like more information on the proposed Hazard Communication updates.