Audit, Compliance and Risk Blog

OSHA: Major Hazcom Revisions Due By June 1, 2015

Posted by Jon Elliott on Tue, May 26, 2015 Occupational Safety and Health Administration (OSHA) adopted massive changes to its Hazard Communication Standard (HCS or Hazcom) effective May 25, 2012, updating chemical information, labeling and training requirements that had been in place since the 1980s. These revised requirements conform U.S. requirements to international guidelines under the U.N.-sponsored Globally Harmonized System of Classification and Labeling of Chemicals (GHS). Recognizing the extent of these changes, OSHA provided multi-year compliance phase-ins for employers whose workers manufacture, distribute or use chemicals. The next such deadline is June 1, 2015, when Safety Data Sheets (SDSs) must replace Material Safety Data Sheets (MSDSs) and end-user employers must ensure that their Hazcom programs reflect most of the revised requirements.

What Information Do SDSs Require?

OSHA requires each SDS to provide at least the following information, including the Section numbers:

  • Section 1, Identification

  • Section 2, Hazard(s) identification

  • Section 3, Composition/information on ingredients

  • Section 4, First-aid measures

  • Section 5, Fire-fighting measures

  • Section 6, Accidental release measures

  • Section 7, Handling and storage

  • Section 8, Exposure controls/personal protection

  • Section 9, Physical and chemical properties

  • Section 10, Stability and reactivity

  • Section 11, Toxicological information

  • Section 12, Ecological information

  • Section 13, Disposal considerations

  • Section 14, Transport information

  • Section 15, Regulatory information

  • Section 16, Other information, including date of preparation or last revision.

Employers must develop, implement, and maintain at each workplace a written hazard communication program. Each program must incorporate the additional SDS information by June 1, into each of the following:

  • List of hazardous chemicals in the workplace, with each product identity referenced to an SDS.

  • System of labeling for workplace containers (which does not have to be fully implemented until June 1, 2016).

  • Methods to inform employees about the hazards of non-routine tasks.

  • Hazards associated with chemicals located in unlabeled pipes in work areas.

  • Training to include the following (this was to have been updated by December 1, 2013):

    • Methods to detect the release of hazardous chemicals into the work area.
    • Hazards of chemicals in the work area, including physical hazards, health hazards, simple asphyxiation, combustible dust, pyrophoric gas, and "not otherwise classified" hazards.
    • Measures employees could take to protect themselves from exposures, including appropriate work practices, emergency procedures, and the proper use of appropriate PPE.
    • Explanations of SDSs [which should continue to consider legacy MSDSs], labels, similar documents, and methods of obtaining and using appropriate hazard information.
OSHA requires that these written programs designate persons responsible for each task (acquiring and filing SDSs, preparing and affixing labels, etc.). The written hazard communication program must be made available, on request, to employees, their representatives, or OSHA/state officials.

Self-Assessment Checklist Process

  • Has the organization prepared a written Hazcom program for each workplace where hazardous chemicals are handled?

  • Does each Hazcom program already meet the GHS standards provided in the revised Hazcom, including detailed hazard determination, classification and response?

  • Has the organization procured an SDS for each hazardous chemical?

    • If not, is there a plan in place to replace existing MSDSs?

  • Has each chemical supplier updated its labeling?

  • Has the organization revised its Hazcom training program(s)?

  • Has the organization scheduled revisions to its workplace labeling practices?

Where Can I Go For More Information?

Specialty Technical Publishers (STP) provides a variety of single-law and multi-law services, intended to facilitate clients’ understanding of and compliance with requirements. These include:

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About the Author Elliott is President of Touchstone Environmental and has been a major contributor to STP’s product range for over 25 years. He was involved in developing 12 existing products, including Environmental Compliance: A Simplified National Guide and The Complete Guide to Environmental Law.

Mr. Elliott has a diverse educational background. In addition to his Juris Doctor (University of California, Boalt Hall School of Law, 1981), he holds a Master of Public Policy (Goldman School of Public Policy [GSPP], UC Berkeley, 1980), and a Bachelor of Science in Mechanical Engineering (Princeton University, 1977).

Mr. Elliott is active in professional and community organizations. In addition, he is a past chairman of the Board of Directors of the GSPP Alumni Association, and past member of the Executive Committee of the State Bar of California's Environmental Law Section (including past chair of its Legislative Committee).

You may contact Mr. Elliott directly at:

Photo credit: corrosive toxic via photopin (license)

Tags: SDS, Health & Safety, OSHA, Environmental, EPA, Hazcom