HazCom and GHS Frequently Asked Questions

The scope and framework of the HCS at 29 CFR 1910.1200 have not changed with this rulemaking. Chemical manufacturers and importers are still responsible for providing information about the hazards of chemicals they produce or import. All employers with hazardous chemicals in their workplaces continue to be required to have a written hazard communication program and to provide information to employees about these hazards and associated protective measures, unless exempted.

According to the agency, the Occupational Safety and Health Administration (OSHA) updated the HCS to improve dissemination of information about chemical hazards. Put another way, the updates ensure “more and better” hazard information to employers and workers, OSHA says. The agency explains that the May 20, 2024, final rule:

• Improves and streamlines precautionary statements
• Provides additional clarification of existing regulatory requirements
• Incorporates new hazard classes and categories
• Increases alignment with other U.S. agencies and international trading partners.

It’s noteworthy that the HCS will no longer align with Revision 3 of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) but instead with Revision 7.

The agency expects a reduced number of worker injuries, illnesses, and fatalities as a result of the updates, but OSHA could not reasonably quantify the numbers.

The notable areas of change to the HCS include the following:

• Adding, revising, and removing definitions
• Maintaining alignment with the GHS
• Addressing issues identified in implementing the 2012 HCS
• Improving alignment and coordination with other U.S. agencies

Twelve terms were impacted by the 2024 final rule. OSHA added the following terms to the definitions at 29 CFR 1910.1200(c):

• Bulk shipment
• Combustible dust
• Gas
• Immediate outer package
• Liquid
• Physician or other licensed health care professional (PLHCP
• Released for shipment
• Solid

The agency revised the following terms:

• Exposure or exposed
• Hazardous chemical
• Physical hazard

Finally, OSHA removed the term pyrophoric gas from the definitions.

The following key changes to the HCS in the 2024 update aimed to maintain alignment with the GHS (primarily Revision 7) and U.S. trading partners (including Health Canada’s WHMIS):

• 1910.1200(f)(12) updates include special labeling provisions for 3 ml and 100 ml containers similar to Health Canada’s WHMIS requirements.
• 1910.1200(i) updates include mandatory use of prescribed concentration ranges when exact percentages or percentage ranges of materials are claimed as a trade secret. The prescribed concentration ranges align with those used by Health Canada’s WHMIS.
• 1910.1200 Appendix A updates align primarily with revised health hazard definitions and general updates to health hazard classes in GHS Revision 7. Updates include, but are not limited to, the skin corrosion/irritation and serious eye damage/eye irritation chapters, with non-animal test methods from GHS Revision 8 added to skin corrosion/irritation to promote use of alternative methods.
• 1910.1200 Appendix B updates align primarily with GHS Revision 7 for physical hazards and include, but are not limited to, flammable gases (expanding hazard categories), desensitized explosives, and aerosols (including additional hazard category).
• 1910.1200 Appendix C updates align primarily with GHS Revision 7 for labeling and include new or updated hazards and updated guidance, hazard statements, and precautionary statements.
• 1910.1200 Appendix D updates align primarily with GHS Revision 7 for safety data sheets (SDSs) and include revisions to SDS Sections 2, 3, 9, and 11.

The following key changes in this update aim to address issues identified during implementation of the 2012 update to the HCS:

• 1910.1200(d)(1) – The final rule clarifies which hazards must be evaluated, including any hazards associated with a chemical’s "intrinsic properties.” A change to physical form and certain chemical reaction products are included.
• 1910.1200(f)(1) – The final rule clarifies the information required and not required on the shipping label.
• 1910.1200(f)(11) – The final rule adds flexibility for label updates on packages that have been released for shipment.
• 1910.1200(f)(12) – The final rule clarifies labeling requirements for small containers.

The following key changes in this update aimed to improve alignment/coordination with other U.S. agencies:

• 1910.1200(c) – The final rule aligns with the Environmental Protection Agency (EPA) for its “released for shipment” definition.
• 1910.1200(f)(5) – The final rule provides increased coordination with Department of Transportation (DOT) requirements for bulk shipments.

Those state-plan states that have their own hazard communication standards must adopt provisions that are at least as effective as federal OSHA’s 2024 HCS final rule. Specifically, within six months of the promulgation date of the final federal rule, state-plan states must adopt the federal standard, complete their own standard, or show that existing state standards are already at least as effective as the new federal standard. The federal promulgation date was May 20, 2024, which puts the six-month point in mid-November 2024.

OSHA will evaluate state-plan states to ensure that any updates do not unduly burden interstate commerce. OSHA finds that IF state-plan states were allowed to require different elements on labels and SDSs from state to state that this COULD disrupt and unduly burden interstate commerce. That’s because it could mean that manufacturers would need to develop different labels and SDSs depending upon the state. Therefore, in the case of the 2024 HCS final rule state-plan states must adopt comparable provisions within six months of publication of the federal final rule.

The 22 states and territories with OSHA-approved occupational safety and health plans that cover public and private-sector employees are Alaska, Arizona, California, Hawaii, Indiana, Iowa, Kentucky, Maryland, Michigan, Minnesota, Nevada, New Mexico, North Carolina, Oregon, Puerto Rico, South Carolina, Tennessee, Utah, Vermont, Virginia, Washington, and Wyoming. Another seven states and territories have OSHA-approved occupational safety and health plans that cover state and local government employees only: Connecticut, Illinois, Maine, Massachusetts, New Jersey, New York, and the Virgin Islands

OSHA has developed a tiered approach for establishments to come into compliance with the revised HCS. The table highlights those dates:

OSHA's HCS (also called the HazCom standard) applies to general industry, shipyard, marine terminal, longshoring, and construction employment and covers chemical manufacturers, importers, distributors, and employers. It is intended to protect employees exposed to hazardous chemicals during normal operations of use or in foreseeable emergencies. Basically, any employer with one employee and one hazardous chemical could be covered. Small employers are not exempt.

However, two types of work operations have limited coverage under 1910.1200 - laboratories and operations where chemicals are only handled in sealed containers (e.g., a warehouse or retail establishment). The limited provisions for these workplaces can be found in paragraphs (b)(3) and (b)(4), respectively. Basically, employers having these types of work operations need only keep labels on containers as they are received, maintain SDSs that are received, give employees access to these SDSs, and provide information and training for employees. (See paragraphs (b)(3) and (b)(4) for the extent of information and training.) Employers do not have to have a written HazCom program or hazardous chemical inventory list for these two types of operations.

It should be noted that the U.S. Department of Labor's Mine Safety and Health Administration (MSHA) issued guidance to the mining industry in 2013 to clarify that mine operators who meet OSHA's HCS will be in compliance with MSHA's HCS.

OSHA explains that the main intent of the written HazCom program requirement is to help ensure that compliance with the HCS is done in a systematic way and that all elements are coordinated. Thus, the program must describe how the employer will address container labeling, collection/availability of SDSs, and employee training.

It also must contain a list of the hazardous chemicals known to be present, along with the means the employer will use to inform employees of both the hazards of non-routine tasks and the hazards associated with chemicals in unlabeled pipes.

Office workers who encounter hazardous chemicals only in non-routine, isolated instances are not covered by the HCS. On the flip side, if workers in office settings are exposed to non-exempt hazardous chemicals under normal operating conditions or in foreseeable emergencies, then they would be covered.

OSHA considers most office products (such as pens, pencils, whiteout, and adhesive tape) to be exempt, either as articles or as consumer products. A complete list of exemptions is found at 29 CFR 1910.1200(b)(6). OSHA has previously stated that intermittent or occasional use of a copying machine does not result in coverage under the standard. However, if an employee handles the chemicals to service the machine, or operates it for long periods of time, then the standard would have to be applied.

A few blanket exemptions for particular substances can be found at 1910.1200(b)(6). These exemptions include:

• Hazardous waste subject to certain regulations;
• Certain hazardous substances when they are the focus of a remedial or removal action;
• Tobacco or tobacco products;
• Wood or wood products under certain conditions;
• Articles as defined at 1910.1200(c);
• Food or alcoholic beverages under certain conditions;
• A drug under certain conditions;
• Cosmetics under certain conditions;
• Any consumer product used as intended for the same duration and frequency that a consumer would use the product;
• Nuisance particulates that do not pose a hazard;
• Ionizing and nonionizing radiation;
• Biological hazards.

GHS stands for the Globally Harmonized System of Classification and Labeling of Chemicals. While the GHS is on its Tenth edition, OSHA’s May 20, 2024, final rule syncs up primarily with the Seventh edition.

The Globally Harmonized System of Classification and Labeling of Chemicals (GHS) is an international approach to hazard communication, providing agreed criteria for the classification of chemical hazards and a standardized approach to label elements and SDSs. The GHS provides harmonized classification criteria for health, physical, and environmental hazards of chemicals. Unlike the GHS, OSHA’s HCS at 29 CFR 1910.1200 has not included the environmental hazards.

Once the hazard classification is completed, the HCS specifies what information is to be provided for each hazard class and category. Hazard communication labels, tags, or markings require the following elements on shipped containers:

• Product identifier - The unique name or number used for a hazardous chemical on a label or SDS. The product identifier used shall permit cross-references to be made among the label, SDS, and list of hazardous chemicals (chemical inventory) required in the written HazCom program.
• Pictogram - A symbol on a white background within a red diamond. There are nine pictograms under the GHS. However, only eight pictograms are required under the OSHA HCS.
• Signal word - A single word on the label is used to indicate the relative level of severity of a hazard and alert the worker to a potential hazard. The signal words used are "Danger" for the more severe hazards, and "Warning" for less severe hazards.
• Hazard statement - A statement assigned to a hazard class and category that describes the nature of the hazard(s) of a chemical, including, where appropriate, the degree of hazard. (Example: Highly flammable liquid and vapor.)
• Precautionary Statement - A phrase that describes recommended measures to be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical. This may also include proper storage or handling of a hazardous chemical, first aid instructions, and disposal requirements.
• Name, U.S. address, and U.S. telephone number of the chemical manufacturer, importer, or other responsible party.

However, 1910.1200(f) offers some labeling flexibility for bulk shipments, containers regulated by the DOT, packages released for shipment, and small containers.

No, OSHA does not have a limit on the number of precautionary statements that appear on the label. OSHA requires all of the appropriate precautionary statements to appear on the label to warn users of the hazards of the chemical in question. However, OSHA does allow for some flexibility when identifying the appropriate precautionary statements for labels, as explained below:

• Precautionary statements may incorporate minor textual variations from the text prescribed in 29 CFR 1910.1200 Appendix C if these variations assist in communicating safety information.
• OSHA allows precautionary statements to be combined or consolidated to save label space. See Appendix C.2.4.6. An example provided in the appendix states: "Keep away from heat, sparks and open flame," "Store in a well-ventilated place" and "Keep cool" can be combined to read "Keep away from heat, sparks and open flame and store in a cool, well-ventilated place."
• Where a chemical is classified for a number of hazards, and the precautionary statements are similar, the most stringent must be included on the label (OSHA expects this to apply mostly to preventive measures) and the less stringent may be omitted.
• Where a substance or mixture is classified for a number of health hazards, and this triggers multiple precautionary statements relating to medical responses, several principles are provided under 29 CFR 1910.1200 Appendix C.2.4.10 regarding prioritization and combining routes of exposure.
• If the chemical manufacturer, importer, or responsible party can demonstrate that a precautionary statement is inappropriate for a specific substance or mixture, it may omit the precautionary statement from the label.

Where hazardous substances are transferred from a labeled container into a portable container, used within a work shift, and under the control of the employee who performs the transfer, then no labels are required on the portable container. However, if the chemical transferred to a portable container is used beyond that shift and/or by other employees who did not perform the transfer, then in-house labeling per 29 CFR 1910.1200(f)(6) is required.

Yes. Employers may choose to label workplace containers either with:

• The same label that would be on shipped containers for the chemical (minus the responsible party contact information), or
• Label alternatives that meet the requirements for 29 CFR 1910.1200(f)(6)(ii).

Alternative labeling systems such as the National Fire Protection Association (NFPA) 704 and the Hazardous Materials Identification System (HMIS) are permitted for workplace containers; however, the information supplied must be consistent with the OSHA HCS. Moreover, since these alternative labels would, at a minimum, only provide the product identifier and "general" information regarding the hazards of the chemicals, the employer must also make "specific" information regarding the physical and health hazards of the chemical immediately available to employees through other means under the hazard communication program.

Moreover, in some cases, all the OSHA chemical hazards are not addressed by a particular rating system (e.g., chronic health hazards). Therefore, hazards not addressed must be communicated by words, pictures, symbols, or a combination thereof in addition to the NFPA or HMIS rating system. If any of the OSHA-required label information is missing, it is not compliant with the HCS.

No. Although the DOT Hazardous Materials Regulations (HMR) prohibits the display on a package of any marking or label that could be confused or conflict with a label required by the HMR, that prohibition does not apply to packages labeled in conformance with certain international standards, including the UN Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The GHS labeling provisions, including as implemented by the OSHA HCS for shipping containers, require all hazard communication elements to be located on the label and these elements must only appear as part of a complete GHS-style label. As such, the display of a marking or label not required by DOT's HMR but conforming to OSHA's HCS and consistent with the GHS is not a violation of the HMR. This includes packages meeting the definition of a "bulk package" as defined by the HMR. In other words, an OSHA HCS-compliant label and a DOT HMR label or marking may both appear on the same package.

What’s more, the 2024 OSHA HCS states, “Where a pictogram required by the [DOT] under title 49 of the Code of Federal Regulations appears on a shipped container, the pictogram specified in appendix C.4 to this section [29 CFR 1910.1200] for the same hazard is not required on the label.”

Yes, Employers are permitted to use color coding to identify chemicals in pipes. Pipes are not required to be labeled with HCS labels because they are not considered "containers" under the standard. Therefore, employees must be informed of and trained on the hazards associated with chemicals in unlabeled pipes, and the measures they can take to protect themselves from these hazards. See the HazCom Training section later in these Frequently Asked Questions for an explanation of training requirements.

Note that other OSHA regulations and other federal, state, or local authorities may require pipe labeling/marking. Where no pipe labeling or marking requirements apply, note that American Society of Mechanical Engineers (ASME) A13.1, Scheme for the Identification of Piping Systems, offers color-coding recommendations.

Where hazardous substances are transferred from a labeled container into a portable container, used within a work shift, and under the control of the employee who performs the transfer, then no labels are required on the portable container. However, if the chemical transferred to a portable container is used beyond that shift and/or by other employees who did not perform the transfer, then in-house labeling per 29 CFR 1910.1200(f)(6) is required.

Yes. Effective July 19, 2024, the HCS has implemented small container labeling provisions at 1910.1200(f)(12). This regulatory paragraph states:

• (f)(12) Small container labelling.
• (i) This paragraph applies where the chemical manufacturer, importer, or distributor can demonstrate that it is not feasible to use pull-out labels, fold-back labels, or tags containing the full label information required by paragraph (f)(1) of this section.
• (ii) For a container less than or equal to 100 ml capacity, the chemical manufacturer, importer, or distributor must include, at a minimum, the following information on the label of the container:
• (A) Product identifier;
• (B) Pictogram(s);
• (C) Signal word;
• (D) Chemical manufacturer’s name and phone number; and
• (E) A statement that the full label information for the hazardous chemical is provided on the immediate outer package.
• (iii) For a container less than or equal to 3 ml capacity, where the chemical manufacturer, importer, or distributor can demonstrate that any label interferes with the normal use of the container, no label is required, but the container must bear, at a minimum, the product identifier.
• (iv) For all small containers covered by paragraph (f)(12)(ii) or (iii) of this section, the immediate outer package must include:
• (A) The full label information required by paragraph (f)(1) of this section for each hazardous chemical in the immediate outer package. The label must not be removed or defaced, as required by paragraph (f)(9) of this section.
• (B) A statement that the small container(s) inside must be stored in the immediate outer package bearing the complete label when not in use

Prior to the effective date, note that OSHA has developed a practical accommodation to address situations where the manufacturer can show that it is not feasible to use pull-out labels, fold-back labels, or tags containing the full HCS required information for shipped small containers (i.e., the actual container holding the hazardous chemical). See OSHA directive CPL 02-02-079. OSHA reviews labeling small packages on a case-by-case basis to determine whether a practical accommodation is warranted.

SDS stands for safety data sheet, formerly known as a material safety data sheet, or MSDS.

Employers must receive a GHS-style, 16-section SDS for each hazardous chemical which they use, except for those products specifically exempted under the HCS at 1910.1200(b)(6).

Employers may contact manufacturers, importers, or distributors of products they have previously ordered from to request new SDSs, and if they do so, the manufacturer or importer must provide the SDS.

However, the HCS does not require employers to contact manufacturers, importers, or distributors to obtain new SDSs of products for which they currently have MSDSs. Therefore, employers must have an SDS or MSDS for each hazardous chemical which they use, but that SDS or MSDS must only be the latest one received.

OSHA defines “health hazard” as “a chemical which is classified as posing one of the following hazardous effects: acute toxicity (any route of exposure); skin corrosion or irritation; serious eye damage or eye irritation; respiratory or skin sensitization; germ cell mutagenicity; carcinogenicity; reproductive toxicity; specific target organ toxicity (single or repeated exposure); or aspiration hazard.” Criteria for determining whether a chemical is classified as a health hazard are found in 29 CFR 1910.1200 Appendix A.

OSHA defines a "physical hazard" as "a chemical that is classified as posing one of the following hazardous effects: explosive; flammable (gases, liquids, or solids); aerosols; oxidizer (gases, liquids, or solids); self-reactive; pyrophoric (liquid or solid); self-heating; organic peroxide; corrosive to metal; gas under pressure; in contact with water emits flammable gas; or desensitized explosive.” Criteria for determining whether a chemical is classified as a physical hazard are found in 29 CFR 1910.1200 Appendix B.

You are not required to have SDSs for household consumer products when the products are used in the workplace for the purpose intended in the same manner that a consumer would use them. Specifically, the exemption is for situations where the employer can show that:

• The chemical is used in the workplace for the purpose intended by the chemical manufacturer or importer of the product
• The use results in a duration and frequency of exposure which is not greater than the range of exposures that could reasonably be experienced by consumers when used for the purpose intended.

Employees who are required to work with hazardous chemicals in a manner that results in a duration and frequency of exposure greater than what a normal consumer would experience would be covered under the HCS, and an SDS would need to be readily accessible in their work areas. Similarly, employees who are required to work with hazardous chemicals in a manner that is not for the purpose intended by the chemical manufacturer or importer would be covered, and an SDS would need to be readily accessible.

Chemicals that do not meet the definition of “hazardous chemical” are not covered by the HCS; therefore, SDSs are not required for chemicals that do not meet that definition. Since OSHA does not require employers to maintain SDSs for chemicals that do not meet that definition, an employer is free to discard SDSs for those chemicals.

However, the employer will want to look at section 2 of the SDS to see if hazards are listed that qualify the chemical as an OSHA hazardous chemical, by definition.

The SDS must be provided and maintained in English. However, the SDS may be translated into other languages that workers speak to aid in comprehension.

In addition, OSHA has said that there is no requirement to translate SDSs (e.g., into a foreign language or braille). Yet, it is recommended that the employer ensure that information from the SDS is available to employees in a manner they would understand easily in case of emergency. Employers may be cited if OSHA-officer interviews reveal that workers do not have an understanding of the chemical hazards they work with or are in their work area.

OSHA 1910.1200(g)(8) states that it is permissible to provide access to SDSs from an electronic work station in the employee's work area provided there are no barriers to immediate employee access in each workplace are created by such options. OSHA directive CPL 02-02-079 goes into further detail. It explains:

• Employees must not be required to perform an Internet search to view/obtain the SDS.
• Employees must have adequate computer access with no restrictions.
• There must be a backup procedure or system (e.g., paper or another electronic system) in case the computer is not functioning.
• Employees must be trained on how to access the SDSs (both on the computer and the backup procedure or system).
• There must be a procedure or system to ensure employees can receive a hard copy if so desired and in cases of emergency (it is not acceptable to only transmit information verbally).
• Employees must not be required to ask for the SDS.

OSHA says employers must train “employees.” The term “employee” is defined at 1910.1200(c) as: “A worker who may be exposed to hazardous chemicals under normal operating conditions or in foreseeable emergencies. Workers such as office workers or bank tellers who encounter hazardous chemicals only in non-routine, isolated instances are not covered.”

"Exposure" or "exposed" under the HCS means that an employee is subjected in the course of employment to a hazardous chemical. This includes potential (e.g., accidental or possible) exposure. ‘‘Subjected’’ in terms of health hazards includes any route of entry (e.g., inhalation, ingestion, skin contact or absorption).

"Normal operating conditions" are those which employees encounter in performing their job duties in their assigned work areas.

However, as stated, workers who encounter hazardous chemicals only in non-routine, isolated instances are not covered. For instance, if a receptionist occasionally delivers a phone message to an area where chemicals are used, the worker would not be covered.

On the flip side, if the receptionist routinely brings messages to that area, the receptionist would be covered by the HCS and must be trained. If an employer is not sure if certain employees are "routinely exposed," the employer should include them in the training. It is better to train too many people than to miss some people and risk an OSHA fine.

OSHA requires that employee HazCom training include at least the:

• Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area (such as monitoring conducted by the employer, continuous monitoring devices, visual appearance or odor of hazardous chemicals when being released, etc.);
• Physical, health, simple asphyxiation, combustible dust, and pyrophoric gas hazards, as well as hazards not otherwise classified, of the chemicals in the work area;
• Measures employees can take to protect themselves from these hazards, including specific procedures the employer has implemented to protect employees from exposure to hazardous chemicals, such as appropriate work practices, emergency procedures, and personal protective equipment to be used;
• Details of the hazard communication program developed by the employer, including an explanation of the labels received on shipped containers and the workplace labeling system used by their employer; the safety data sheet, including the order of information and how employees can obtain and use the appropriate hazard information.

In addition, employees must be informed of:

• The requirements of 29 CFR 1910.1200;
• Any operations in their work area where hazardous chemicals are present;
• The location and availability of the written hazard communication program, including the required list(s) of hazardous chemicals, and safety data sheets required by the HCS.

Note that while the 2024 HCS did not change the provisions of 29 CFR 1910.1200(h), it may be required that employers update their training program and provide additional employee training for newly identified physical, health, or other hazards by the compliance dates listed in 1910.1200(j).

Employers must provide “effective” HazCom training to their employees at the time of their initial assignment and whenever a new chemical hazard the employees have not previously been trained about is introduced into their work area. This does not mean when a new chemical is introduced but rather when a new hazard is introduced.

For example, if a new solvent is brought into the workplace, and it has hazards similar to existing chemicals for which training has already been conducted, then no new training is required. If the newly introduced solvent is a suspect carcinogen, and there has never been a carcinogenic hazard in the workplace before, then new training for carcinogenic hazards must be conducted for employees in those work areas where employees will have exposure.

The HCS requires that the host and the contractor exchange information so each can train their own workers. However, the contractor and host employer may share responsibility to provide training to contract employees if the host employer is a creating, exposing, correcting, or controlling employer per OSHA directive CPL 02-00-124. The contract between the contractor and the host employer should spell out who would be expected to provide generic and/or site-specific HazCom training. Often the contractor provides generic training, while the host employer provides site-specific HazCom training for chemicals found at the site.

Staffing agencies and host employers are jointly responsible for training temporary employees. Staffing agencies must, at a minimum, provide generic training. The host employer holds the primary responsibility for training since it uses or produces chemicals, creates, and controls the hazards and is best suited to provide temporary employees with site-specific training. Refer to OSHA’s Temporary Worker Initiative (TWI) Bulletin No. 5 - Hazard Communication (OSHA 3860 - 2016) for further information.