The three major areas of change are in hazard classification, labels, and safety data sheets.
- Hazard classification: The definitions of hazard have been changed to provide specific
criteria for classification of health and physical hazards, as well as classification of mixtures. These
specific criteria will help to ensure that evaluations of hazardous effects are consistent across
manufacturers, and that labels and safety data sheets are more accurate as a result.
- Labels: Chemical manufacturers and importers will be required to provide a label that
includes a harmonized signal word, pictogram, and hazard statement for each hazard class and category.
Precautionary statements must also be provided.
- Safety Data Sheets: Will now have a specified 16-section format.
The GHS does not include harmonized training provisions, but recognizes that training is essential to an
effective hazard communication approach. The revised Hazard Communication Standard (HCS) requires that workers
be re- trained within two years of the publication of the final rule to facilitate recognition and
understanding of the new labels and safety data sheets.
For a side-by-side comparison of the current HCS and the final revised HCS please see OSHA's hazard
communication safety and health topics webpage at: http://www.osha.gov/dsg/hazcom/index.html
What is the phase-in period in the revised Hazard Communication Standard?
The table below summarizes the phase-in dates required under the revised Hazard Communication Standard
employees on the new label elements and safety data sheet (SDS) format.
December 1, 2015
Compliance with all modified provisions of this final rule, except:
The Distributor shall not ship containers labeled by the chemical manufacturer or importer
unless it is a GHS label
manufacturers, importers, distributors and employers
alternative workplace labelling and hazard communication program as necessary, and provide
additional employee training for newly identified physical or health hazards.
Transition Period to the effective completion dates noted above
comply with either 29 CFR 1910.1200 (the final standard), or the current standard, or both
manufacturers, importers, distributors, and employers
*This date coincides with the EU implementation date for classification of mixtures
During the phase-in period, employers would be required to be in compliance with either the existing HCS
or the revised HCS, or both. OSHA recognizes that hazard communication programs will go through a period of
time where labels and SDSs under both standards will be present in the workplace. This will be considered
acceptable, and employers are not required to maintain two sets of labels and SDSs for compliance
What Hazard Communication Standard provisions are unchanged in the
The revised Hazard Communication Standard (HCS) is a modification to the existing standard. The parts
of the standard that did not relate to the GHS (such as the basic framework, scope, and exemptions)
remained largely unchanged. There have been some modifications to terminology in order to align the
revised HCS with language used in the GHS. For example, the term "hazard determination" has been
changed to "hazard classification" and "material safety data sheet" was changed to "safety data sheet."
OSHA stakeholders commented on this approach and found it to be appropriate.
How will chemical hazard evaluation change under the revised Hazard
Under both the current Hazard Communication Standard (HCS) and the revised HCS, an evaluation of
chemical hazards must be performed considering the available scientific evidence concerning such
hazards. Under the current HCS, the hazard determination provisions have definitions of hazard and
the evaluator determines whether or not the data on a chemical meet those definitions. It is a
performance-oriented approach that provides parameters for the evaluation, but not specific,
detailed criteria. The hazard classification approach in the revised HCS is quite different. The
revised HCS has specific criteria for each health and physical hazard, along with detailed
instructions for hazard evaluation and determinations as to whether mixtures or substances are
covered. It also establishes both hazard classes and hazard categories—for most of the effects; the
classes are divided into categories that reflect the relative severity of the effect. The current
HCS does not include categories for most of the health hazards covered, so this new approach
provides additional information that can be related to the appropriate response to address the
hazard. OSHA has included the general provisions for hazard classification in paragraph (d) of the
revised rule, and added extensive appendixes (Appendixes A and B) that address the criteria for
each health or physical effect.
How will labels change under the revised Hazard Communication
Under the current Hazard Communication Standard (HCS), the label
preparer must provide the identity of the chemical, and the appropriate hazard warnings. This
may be done in a variety of ways, and the method to convey the information is left to the
preparer. Under the revised HCS, once the hazard classification is completed, the standard
specifies what information is to be provided for each hazard class and category. Labels will
require the following elements:
- Pictogram: a symbol plus other graphic elements, such as a border,
background pattern, or color that is intended to convey specific information about the
hazards of a chemical. Each pictogram consists of a different symbol on a white background
within a red square frame set on a point (i.e. a red diamond). There are nine pictograms
under the GHS. However, only eight pictograms are required under the HCS.
- Signal words: a single word used to indicate the relative level of
severity of hazard and alert the reader to a potential hazard on the label. The signal
words used are "danger" and "warning." "Danger" is used for the more severe hazards, while
"warning" is used 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.
- Precautionary Statement: a phrase that describes recommended measures
to be taken to minimize or prevent adverse effects resulting from exposure to a hazardous
chemical, or improper storage or handling of a hazardous chemical.