GHS Hazcom Update May Land Before Year’s End | Dec. 2022 Safety Advisor

OSHA plans to issue a Final Rule to align its Hazard Communication Standard with the seventh revised edition of the Globally Harmonized System for Classifying and Labeling Chemicals (GHS) in December 2022.

Proposed changes to the Hazard Communication Standard (HCS) for chemical manufacturers, importers, distributors, and employers will impact labeling of chemical containers, hazard classification, Safety Data Sheet (SDS) requirements, and more.

Labeling Small Containers

The proposed update would codify a number of existing OSHA interpretations related to labeling of containers that are too small to fit a full GHS-style label.

A new paragraph (f)(12) would allow for reduced information to appear on small containers when it is demonstrated that using a pull-out label, fold-back label, or tag is not feasible.
Containers less than or equal to 100 ml capacity would require:

  • A product identifier
  • Pictograms
  • Signal word
  • Chemical manufacturers’ name and phone number
  • A statement that the full label information is provided on the immediate outer package.
  • For containers less than or equal to 3 ml capacity, OSHA would require only the product identifier to appear on the immediate container, such as a vial.

OSHA also proposes to require the immediate outer package to include:

  • Full label information
  • A statement indicating that the smaller containers inside must be stored in the immediate outer package when not in use.

GHS Labels on Bulk Chemical Shipments

For bulk shipments, OSHA would allow for labels to be placed on the immediate container, like is currently required, or be transmitted with shipping papers or bills of lading (or electronically) as long as the label is available to workers in printed form at the receiving end of the shipment. This would be added to paragraph (f)(5). That paragraph would be re-titled “Transportation.”

Updating Hazard Labels

When a chemical manufacturer, importer, distributor, or employer learns significant new information about the hazards of a chemical, paragraph (f)(11) requires them to update container labels within 6 months.

New HCS Hazard Classes & Categories

The proposed rule would add one new hazard class: Desensitized explosives.

Three new hazard categories would be added as well. Under the Flammable Gases class, OSHA would add categories for unstable gases and pyrophoric gases. Under the Aerosols class, OSHA would add a category
for nonflammable aerosols.

OSHA is also proposing to add a new sentence to the hazard classification requirements in 29 CFR 1910.1200(d)(1) that would require the classification to include “any hazards associated with a change in the chemical’s physical form or resulting from a reaction with other chemicals under normal conditions of use.”

Trade Secrets on Safety Data Sheets

OSHA proposes two significant changes concerning trade secrets that may appear on a Safety Data Sheet.

The proposed rule would allow manufacturers, importers, and employers to withhold a chemical’s concentration range as a trade secret.  OSHA also requested comment on whether the Agency should adopt a set schedule for updating the HCS in the future, such as updating the HCS every four years or updating after every two GHS revisions.

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