United States Office of Solid Waste EPA 550-F-12-001
Environmental Protection and Emergency Response Aug 2012
Agency www.epa.gov/emergencies
REVISIONS TO THE OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION
HAZARD COMMUNCATION STANDARD (HCS)
On March 26, 2012, Occupational Safety and Health Administration (OSHA) modified its Hazard
Communication Standard (HCS) to conform to the United Nations' (UN) Globally Harmonized System
of Classification and Labeling of Chemicals (GHS). The revisions will improve consistency and quality
of information that is provided to both employers and employees concerning chemical hazards and
protective measures related to chemical hazards.
What is the Globally Harmonized System of Classification and Labeling of Chemicals?
GHS is a system developed by the UN to strengthen international efforts concerning the
environmentally sound management of chemicals. It was recognized that an internationally
harmonized approach to classification and labeling would provide the foundation for all countries to
develop comprehensive national programs to ensure the safe use of chemicals. GHS establishes a
set of criteria and provisions that regulatory authorities, such as OSHA, can incorporate into their
existing regulations or standards, or use to develop a new system. Regulatory authorities are not
required to adopt all of the criteria that are defined in GHS, only those that are appropriate to their
specific regulations.
GHS includes harmonized provisions for classification of chemicals for their health, physical and
environmental effects, as well as for labels on containers and safety data sheets (SDSs, formerly
"Material Safety Data Sheets, or MSDSs). The definitions of hazards in GHS are more specific and
detailed than in HCS prior to the adoption of GHS provisions. Under the GHS, each hazard (e.g.,
explosives, carcinogenicity) is considered to be a hazard class. The classes are sub-divided into
categories of hazard. For example, carcinogenicity has two hazard categories; category one is for
known or presumed human carcinogens while category two is for suspected human carcinogens.
GHS provisions require manufacturers and importers to classify their chemicals using these specific
criteria.
GHS provisions also require manufacturers and importers to classify mixtures using a tiered
approach. GHS specifies using pictograms and precautionary statements on container labels. GHS
also establishes a standardized 16-section format for SDSs to provide consistent sequence of
information for users.
HCS Prior to Adopting GHS Provisions
HCS was first promulgated in 1983 and it required chemical manufacturers and importers to evaluate
hazards of the chemicals they produce or import and transmit this information on container labels and
MSDSs to downstream users of the chemicals. HCS also required employers to train employees who
are exposed to hazardous chemicals and provide them access to MSDSs. The standard was
performance-oriented, providing definitions of hazards and parameters for evaluating the evidence to
determine whether a chemical is hazardous. The evaluation is based upon evidence that is currently
available and no testing of chemicals is required. HCS established requirements for minimum
information that must be included on labels and MSDSs, but did not provide specific language to
convey the information or a specific format in which to provide it. Some chemical manufacturers and
importers followed a specified format for MSDSs developed under a voluntary consensus standard
(ANSI Z400.1), which was later adopted by GHS with minor changes.
Office of Emergency Management
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Revisions to OSHA's Hazard Communication Standard
Aug 2012
Summary of Changes to the HCS
• Hazard Classification: Chemical manufacturers and importers are required to re-evaluate
chemicals according to the new criteria adopted from GHS in order to ensure that pure
chemicals and mixtures are classified appropriately. The new criteria must be provided to
downstream users in revised SDSs.
• Labels: Chemical manufacturers and importers must provide a label which includes a signal
word, pictogram, hazard statement, and precautionary statement for each hazard class and
category.
• Safety Data Sheets: The new format contains 16 specific sections with headings for each
section, which ensures consistency in presentation of information. Chemical manufacturers
and importers are required to distribute modified safety data sheets to downstream users of
their chemicals.
• Information and training: To facilitate understanding of the new system, the standard
requires that workers be trained on the new label elements and safety data sheet format.
Effective Dates for Provisions in HCS:
Effective Completion
Date
Requirement(s)
Who
December 1, 2013
Train employees on the new label elements
and SDS format.
Employers
June 1, 2015
December 1, 2015
Comply with all modified provisions for
preparation of new labels and safety data
sheets, except:
Distributors shall not ship containers labeled
by the chemical manufacturer or importer
unless it is a GHS label.
Chemical
manufacturers,
importers, distributors
and employers
June 1,2016
Update alternative workplace labeling and
hazard communication program as
necessary, and provide additional employee
training for newly identified physical or
health hazards.
Employers
Transition Period (May
25, 2012 to the
effective completion
dates noted above)
Comply with either the revised HCS
published on March 26, 2012 or the
standard that were in effect prior to adopting
GHS provisions.
All chemical
manufacturers,
importers, distributors
and employers
Office of Emergency Management
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Revisions to OSHA's Hazard Communication Standard Aug 2012
How do changes to HCS affect Sections 311 and 312 of the Emergency Planning and
Community Right-to-Know Act (EPCRA)?
Certain provisions of EPCRA sections 311 and 312 and the implementing regulations may be
affected due to the revisions in HCS, mainly the requirement for submitting material safety data sheet
(MSDS) under section 311. The reporting requirements under EPCRA section 311 (a) and its
implementing regulations codified in 40 CFR part 370 apply to the owner and operator of a facility
required to prepare or have available an MSDS under OSHA HCS for any hazardous chemical. The
owner or operator of the facility must submit the MSDS or a list containing all hazardous chemicals to
their State Emergency Response Commission (SERC), local emergency planning committee (LEPC)
and the local fire department if the reporting thresholds specified in 40 CFR part 370 are met. Section
311 (d)(2) of EPCRA requires an owner or operator to submit a revised MSDS to the SERC, LEPC
and the local fire department within 3 months of finding significant new information about the
hazardous chemical for which an MSDS was previously submitted.
However, states were always given the flexibility to implement EPCRA as needed to meet the goals
of EPCRA in their communities. Each state may have specific requirements for submitting information
under sections 311 and 312, including electronic reporting. Facilities are encouraged to contact their
states regarding the submission of revised SDSs.
Where Do I Go For More Information?
For more information on hazard communication standards, including the link to the final rule
published in the Federal Register on March 26, 2012, please visit OSHA's hazard communication
safety and health topics page: http://www.osha.gov/dsg/hazcom/index2.html.
Office of Emergency Management
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