Washington — OSHA has revised its inspection procedures to align with the agency’s updated standard on hazard communication (1910.1200), issued in 2024.
In a May 19 memo, OSHA references Paragraph (i) – trade secrets, Appendix A (health hazard criteria), Appendix B (physical hazard criteria) and Appendix C (allocation of label elements), along with revisions to Safety Data Sheet Sections 1-3, 8-11 and 14 in Appendix D.
The agency also seeks to provide clarity on issues found during the implementation of its previous HCS update in 2012. Those issues relate to:
- Hazard classification, Paragraph (d)
- Label updates, Paragraph (f)(11)
- Small and very small container labeling, Paragraph (f)(12)
Additionally, OSHA seeks to improve alignment with other federal agencies. The memo addresses Paragraph (f)(5), which provides increased coordination with the Department of Transportation’s label for bulk shipments, and Paragraph (c), which aligns with the Environmental Protection Agency’s definition of “released for shipment.”
The HazCom standard is currently aligned to the seventh revision of the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals, also known as GHS. GHS is on its 11th revision, which was published Dec. 9.
Part of the new rules went into effect May 19 for chemical manufacturers, importers and distributors who are evaluating substances. The compliance date for evaluating mixtures is Nov. 19, 2027.
Employers using products covered under the standard must update their hazcom programs, labeling and employee training by Nov. 20, 2026, or May 19, 2028 – also depending on substances or mixtures, respectively.
The memo cancels a previous directive from 2015.
