OSHA Rules Change To Hazard Communication Standard

Originally published March 2010

In September 2009, the Occupational Safety and Health Administration ("OSHA") proposed a change to its nearly three-decade-old Hazard Communication Standard (the "HCS") in an effort to align the HCS with the United Nations Globally Harmonized System of Classification and Labeling of Chemicals ("GHS"). OSHA argues that the rule change is necessary to improve the quality and consistency of information provided to workers, employers and chemical users. The proposed rule, the agency claims, will achieve this by adopting a standardized approach to hazard classification, labels and safety data.

Currently, the HCS (at 29 CFR §1910.1200) requires that chemical manufacturers and importers evaluate the chemicals they produce or import and provide hazard information to downstream employers and workers in the form of packaging labels and material safety data sheets. Under the proposed rule, which is modeled after the GHS, OSHA claims that