OSHA’s Hazard Communication Standard (HCS) update became effective July 19, 2024, bringing many substantive changes yet leaving HCS’ structure unchanged. OSHA expects it to reduce incidents with a minimal learning curve for downstream users because the look and feel of safety data sheets (SDS) and most labels remain unchanged, but they will have better hazard classifications (the changes to Appendices A and B convey potential health and physical hazard risks more clearly to users). Other factors, such as a long compliance lead time, should keep training and other costs associated with the HCS update minimal for most employers. Hazardous communications and training programs, for which OSHA states in the final rule’s preamble it will publish related guidance documents, must be updated by July 19, 2026, with an additional eighteen-month allowance for mixtures.

Chemical manufacturers, distributors, and importers have until January 19, 2026, and July 19, 2027 (for substances and mixtures, respectively) to issue labels and SDS that reflect the new HCS requirements. Such companies are most impacted by the HCS update, but some of its changes should lower costs. For example, a clarifying revision to  1910.1200(d) now explains that manufacturers shall consider their customers’ “reasonably anticipated uses or applications” in assigning hazard classifications. However, another change refers to that same provision to grant relief from the label update requirement. Now, shipped containers with long supply chains are not required to retain their original labeling if paragraph (d) uses or applications change. Also, trade secrets provisions for chemical mixtures now conform to the Canadian standard, requiring less detail, and allowing the same SDS to be used by Canadian and U.S. workers alike.

Another area of cost savings comes from aligning with seventh revision (Rev. 7) of the Globally Harmonized System of Classification and Labelling of Chemicals (GHS). Now HCS is aligned with other U.S. agencies and international trading partners such as Canada and the EU, which have all adopted Rev. 7. All told, this harmonization, conservation of basic HCS framework, and making HCS documentation more efficient have led OSHA to project that the implementation of the new HCS will result in national annual cost savings of $30M.

Effective July 1, 2024, California’s Department of Toxic Substances Control (DTSC)  adopted the federal EPA’s Generator Improvements Rule (GIR), in the first of two rulemaking packages. The changes significantly amend, recodify, and restructure rules applicable to small quantity generators, very small quantity generators, and large quantity generators in relation to acute hazardous waste, extremely acute hazardous waste, and non–acute hazardous waste.

The provisions DTSC included in this first rulemaking package are all more stringent than the provisions they replace, which made their adoption by the Department mandatory. These include 1) a new generator re-notification requirement, 2) new marking and labeling requirements for containers and tanks, 3) new requirements for closures and satellite accumulation areas, and 4) new spill procedure-related requirements for small and large quantity generators. The new structure now mirrors the federal rule for better comprehension.

OSHA’s Hazard Communication Standard (HCS) update became effective July 19, 2024, bringing many substantive changes yet leaving HCS’ structure unchanged. OSHA expects it to reduce incidents with a minimal learning curve for downstream users because the look and feel of safety data sheets (SDS) and most labels remain unchanged, but they will have better hazard classifications (the changes to Appendices A and B convey potential health and physical hazard risks more clearly to users). Other factors, such as a long compliance lead time, should keep training and other costs associated with the HCS update minimal for most employers. Hazardous communications and training programs, for which OSHA states in the final rule’s preamble it will publish related guidance documents, must be updated by July 19, 2026, with an additional eighteen-month allowance for mixtures.

Chemical manufacturers, distributors, and importers have until January 19, 2026, and July 19, 2027 (for substances and mixtures, respectively) to issue labels and SDS that reflect the new HCS requirements. Such companies are most impacted by the HCS update, but some of its changes should lower costs. For example, a clarifying revision to  1910.1200(d) now explains that manufacturers shall consider their customers’ “reasonably anticipated uses or applications” in assigning hazard classifications. However, another change refers to that same provision to grant relief from the label update requirement. Now, shipped containers with long supply chains are not required to retain their original labeling if paragraph (d) uses or applications change. Also, trade secrets provisions for chemical mixtures now conform to the Canadian standard, requiring less detail, and allowing the same SDS to be used by Canadian and U.S. workers alike.

Another area of cost savings comes from aligning with seventh revision (Rev. 7) of the Globally Harmonized System of Classification and Labelling of Chemicals (GHS). Now HCS is aligned with other U.S. agencies and international trading partners such as Canada and the EU, which have all adopted Rev. 7. All told, this harmonization, conservation of basic HCS framework, and making HCS documentation more efficient have led OSHA to project that the implementation of the new HCS will result in national annual cost savings of $30M.