OSHA’s Updated Hazard Communication Standard (HCS): What’s Changed & How to Stay Compliant

 The Hazard Communication Standard (HCS), often referred to as HazCom, is a set of OSHA rules that ensures chemical safety in the workplace by making chemical identities and hazards available and understandable to workers. The HCS has just gone through major changes. In this article, we’ll cover:  

1. What is new in the Hazard Communication Standard.  
2. Why companies are struggling to keep up with the HCS. 
3. What are the strategies for meeting the new HCS. 

Amendments to the Hazard Communication Standard 

The HCS underwent a major update in May 2024, with the new rules officially kicking in on July 19th. The main change is that the standard is now aligning more closely with the 7th edition of the UN’s Globally Harmonized System for chemical classification and labeling. Some of the key changes to the HCS include: 

• Hazard Classification –Manufacturers must be more thorough when classifying the hazards of their chemicals, with specific criteria. Cutting corners is no longer an option. Manufacturers can no longer rely on incomplete or outdated data when classifying hazards. They must also account for the synergistic effects of chemicals in mixtures that were often overlooked in the past.

• Labeling Flexibility – Provisions have been added to allow reduced information on small packages where full   labeling is not possible. 

• Bulk Shipments – Unified labeling regulations between OSHA and the Department of Transportation (DOT) have been introduced to simplify dual labeling requirements. 

• Extended Compliance Dates – Compliance dates have been extended, with an earliest deadline of January 19, 2026 for chemical substances, and a latest deadline of January 19, 2028, for mixtures. 

Struggles with Hazard Communication (HazCom) Compliance 

As someone who has worked in chemical safety for over 20 years, I’ve seen firsthand how challenging Hazard Communication compliance can be. Despite the critical importance of HazCom, many organizations struggle with staying compliant. With 3,213 instances, Hazard Communication violations were the second most frequently cited OSHA violation in 2023, highlighting these struggles to maintain HazCom compliance.   

Here are a few of the most common struggles with maintaining HazCom compliance: 

• Documentation and Accessibility – Maintaining and accessing Safety Data Sheets (SDS) can be difficult, especially for organizations dealing with many hazardous chemicals. Smaller organizations often lack the resources to maintain comprehensive digital databases. This inadequacy leads to reliance on outdated or incomplete information. 

• Management Support and Funding – Getting executive management to diligently prioritize and fund HazCom programs is easier said than done. With all the other demands of the organization on their time and money, a lot of companies just don’t make chemical safety the priority that it needs to be. 

• Training and Awareness – Keeping everyone on your team informed and properly trained about the chemical hazards they may encounter is an ongoing battle. And it only gets harder when you have a high turnover rate or are constantly introducing new chemicals and processes to the workplace. 

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Best Practices for Effective HazCom Implementation 

To overcome these challenges and ensure compliance with the updated HCS, Hazard Communication teams should consider the following steps: 

1. Learn the Hazard Communication Standard – Familiarize yourself with the provisions of the updated HCS. Identify staff responsible for coordinating the implementation and ensure they are well-informed about the requirements. 
2. Prepare a Written Hazard Communication Program – First things first. You should put together a detailed HazCom plan that covers all your bases: compiling an inventory of hazardous chemicals, setting up labeling systems, maintaining your SDSs, and making sure employees get the right training. 
3. Ensure Proper Labeling – Implement the updated labeling requirements, especially for small packages and bulk shipments. Make sure that all containers are properly labeled with the necessary hazard information. 
4. Maintain and Update SDS – Create a centralized, easily accessible digital database for SDS. Don’t forget to stay on top of updating those safety data sheets! Make sure the SDS containing the latest information, especially when there are changes to the classification of chemicals.  
5. Employee Training – Conduct regular, mandatory training sessions to educate employees on the hazards of chemicals they may encounter, proper handling procedures, and emergency response protocols. Training should be ongoing and updated as new chemicals are introduced. 
6. Evaluate and Reassess – Keep checking in on how well your HazCom program is working and be ready to adapt as new hazards come up, or your workplace changes. You can’t just set it and forget it – effective HazCom compliance is an ongoing process. 

Conclusion 

So, there you have it – if you can get a handle on the new HCS rules, tackle those common HazCom headaches, and take a proactive approach, you’ll be well on your way to creating a safer workplace and protecting your employees from chemical risks. It’s a lot of work, but it is worth the reduced injuries and lives saved.