OSHA HCS 2024 Final Rule Published

Written By Valence Regulatory

OSHA HCS 2024 Final Rule Published – What Chemical Distributors Need to Know

The Occupational Safety and Health Administration (OSHA) has officially published the 2024 Hazard Communication Standard (HCS) Final Rule, marking a significant alignment of US regulations with the United Nations Globally Harmonized System (GHS) Revision 7.

For chemical distributors and private label manufacturers, this update triggers a mandatory review of your entire Safety Data Sheet (SDS) library and labeling strategy.

Key Changes in the 2024 Rule

1. "Flammable Aerosols" Renamed The category is now simply "Aerosols" and includes a new Category 3 for non-flammable aerosols. If you manufacture or distribute spray products, your current classification logic may be obsolete.

2. Concentration Ranges for Trade Secrets In a move that harmonizes US rules with Canada’s WHMIS, manufacturers can now use standardized prescribed concentration ranges (e.g., 1-5%, 10-30%) when claiming trade secret protection for ingredients. This allows for a cleaner, dual-compliant North American SDS without the need for complex "Trade Secret" claims in specific circumstances.

3. Small Container Labeling Relief For containers under 100ml, OSHA now allows abbreviated labeling if the full text physically cannot fit. This is a critical update for cosmetic and essential oil distributors who have struggled with compliance on small vials.

4. Section 9 Overhaul: Physical Properties While many updates focus on classification, the 2024 Final Rule also mandates specific changes to the data fields in Section 9 (Physical and Chemical Properties) to align with GHS Revision 7.

  • "Particle Characteristics": This is a new mandatory field that must be included for solid substances. You must now describe properties like size, size distribution, and shape, which are critical for assessing combustible dust hazards.

  • Revised Order: The list of properties has been reordered to match the international GHS standard, ensuring consistency when authoring for global markets.

  • Why this matters: If your authoring software or Word templates are still using the 2012 field list, your Section 9 will be missing required data points, making the document technically non-compliant even if the hazards are correct.

Implementation Deadlines

While the rule is effective immediately (July 19, 2024), OSHA has provided a transition period:

  • January 19, 2026: Compliance deadline for Substances.

  • July 19, 2027: Compliance deadline for Mixtures.

Is Your Library Ready? If your SDSs were authored prior to July 2024, they do not reflect these new standards. Contact Valence Regulatory today for a library audit to ensure your documentation meets the new federal requirements.

 

Note: This article is based on the regulations available as of May 20th, 2024. Compliance requirements vary by product and region. Contact Valence Regulatory for a specific assessment of your obligations.

Valence Regulatory