OSHA’s updated HazCom standard: What’s changed?

OSHA’s updated standard on hazard communication (1910.1200) officially went into effect July 19. The standard now aligns the agency’s regulations with those of the seventh revision of the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals – better known as GHS.

Richard Fairfax, former deputy assistant director at OSHA and now a principal consultant for the National Safety Council, discussed the standard and its recent updates during the July episode of Safety+Health’s “On the Safe Side” podcast.

Here are some highlights from the interview.

Compliance dates

Although the updated standard is now in effect, Fairfax noted that OSHA is providing ample time for compliance with its requirements. For instance, the agency is giving chemical manufacturers, importers and distributors until Jan. 19, 2026, to comply with the new rules. Some entities have even longer.

“If you’re an employer and you’re using chemicals, and you’re having to generate data sheets or produce labels, you have until July 20, 2026,” Fairfax said. “If your product is a chemical mixture, and you’re a chemical manufacturer or importer, you have until July 19, 2027.

“Likewise, if you’re an employer that’s generated a mixture and having to produce data sheets or labels, you have until Jan. 19, 2028.”

For employers, compliance may mean updating any training or written HazCom programs.

OSHA has stated that, until those dates, employers, chemical manufacturers, distributors and importers can comply with either the old or new standard – or both – during the transition period.

Safety Data Sheets

Safety Data Sheets are now required to have 16 sections, which will “basically have to follow a similar order,” Fairfax said.

“OSHA has always alluded to a 16-section format for data sheets, but that actually wasn’t a requirement (under the previous standards),” he added.

The change means, for example, that a worker looking through an SDS to learn about the necessary personal protective equipment will “know to go to the same section rather than having to thumb through different data sheets to look at different requirements.”

Labels

Among the changes for labeling, the updated standard allows for foldout labels, like those on certain medicine bottles. Under the previous HazCom standard, Fairfax said, complying with labeling requirements for smaller containers or having that information in a readable format could prove difficult at times.

Another change for labels is the use of a GHS pictogram or a Department of Transportation pictogram.

Previously, Fairfax noted, if the DOT pictogram was different than the GHS pictogram, both had to be included on the label, which was “quite confusing.”

He said the updated standard “allows some flexibility, which finally is a good thing.”

Another bit of flexibility: If an employer uses a chemical straight out of the container it was shipped in, they’re allowed to keep the label on the container instead of having to generate a new label.

The old way was “a little bit redundant,” Fairfax said.

“This update recognizes that problem from before and basically says, ‘If a shipping container is the use container at the site, you don’t have to do anything with it if it’s got the right label on it.’”

Trade secrets

OSHA’s HazCom standard, including the updated version, allows manufacturers or importers to indicate on an SDS “that the specific chemical identity and/or the exact percentage of composition of a hazardous ingredient is being withheld as a trade secret.”

One issue, Fairfax said, was that the concentration of a chemical – say, sulfuric acid – could be listed as 1% to 99%.

“If it’s 1% sulfuric acid or 90%, it makes a difference,” he added.

The updated standard follows the Canadian system for trade secrets – a smaller range for listing concentrations in a chemical product.

“They can get away without labeling what the chemical is – that’s a trade secret – but the standard spells out prescribed ranges,” Fairfax said. “For instance, if there’s 52% of this particular chemical in the solution, they can say it’s from 30% to 60%.”

New hazard classes

OSHA has also made changes for some chemical and physical hazards. Among them, Fairfax highlighted:

• Adding pyrophoric gases and unstable gases to flammable gases
• Changing “flammable aerosols” to “aerosols”
• Defining nonflammable aerosols
• Adding “chemicals under pressure” to the aerosol definition
• Revised oxidizing solids testing
• Adding desensitized explosives into Appendix B (physical hazards)

For toxicity, the updated HazCom standard now allows for testing results that use effects on people instead of strictly animal testing.

“Things like the Ames test or other testing operations are acceptable under the standard,” Fairfax said. “Human toxicity of chemicals was (previously) based solely on animal data.”

However, for example, “there’s a lot of human data available from benzene for a lot of companies that exclusively use benzene,” Fairfax said. “It allows the human data from facilities and sites to come into play.”