Compliance Corner: OSHA’s Proposed Changes to the Hazard Communication Standard

In April, 2021, the Occupational Safety & Health Administration extended the comment period for new proposed updates to the 29 CFR 1910.1200 Hazard Communication standard. Stakeholders, employers, employees, and the general public now have until May 19, 2021 to review the proposal and make necessary comments concerning the proposed changes.

It is anticipated that the new proposals will increase worker protection, and injury reduction by completing the following:

(a.) Improving chemical labelling

(b.) Improving Safety Data Sheet information

(c.) Improve alignment with other Federal Agencies and Canada

Some Proposed Changes Include:

(1.) Requirements for the Chemical Manufacturer to add the date that the chemical is released for shipment.

(2.) Requirements for the Chemical Manufacturer to classify chemicals under normal conditions of use and foreseeable emergencies. The classifications must include any changes in the physical form of chemical as a result of interaction with another chemical under normal conditions of use.

(3.) Chemical labels for bulk shipments of hazardous waste may be transmitted with Shipping papers, bills of lading, or other technological or electrical means so that it is immediately available to workers in printed form on the receiving end of the shipment.

(4.) Pictograms required by the Department of Transportation (DOT) on shipping containers, will not be required on labels of the same hazard.

(5.) Requirements for Chemical Manufacturers to label Containers less than or equal to 100 ml with the following minimum information:

• Product Identifier
• Pictogram
• Signal Word
• Manufacturer name and Phone Number
• A statement that the full label information on the hazard is provided on the immediate outer package.

(6.) Containers less than or equal to 3 ml are not required to be labelled, if the manufacturer, importer, or distributor can demonstrate that the label interferes with normal use of the container. However, the container must contain at minimum, the product identifier.

The aforementioned items, along with other proposed changes are designed to ensure both the employer and employees are provided vital and important information needed to protect themselves from injuries and incidents involving hazardous chemicals in the workplace. Stay tuned for more updates, changes, and comments regarding new proposals to OSHA’s Hazard Communication standard (29 CFR 1910.1200)