It is Finally Happening – OSHA HCS is on the Move
We have all been waiting for the updated OSHA Hazard Communication Standard (HSC) Part 1910.1200. Initially, it was suspected to be released at the same time as Health Canada released their update to the Hazardous Products Regulations (WHMIS). Well, in December 2022, Health Canada published Gazette II, but OSHA’s update was nowhere to be had.
Finally, there is a sign of movement. The OSHA HCS update finally went to OMB ON 10/11/2023. The OMB review period can be up to 90 days, so we can expect a final rule to be published in the Federal Register by about mid-January 2024.
What can we expect?
The U.S. Health and Safety Administration (OSHA) will update hazard communication for workplace chemicals to at least the seventh revised edition of the “Purple Book”, from the third revised edition.
Some of the classification changes may include:
- Flammable Gases – Category 1 (extremely flammable gases) will be divided into subcategories 1A and 1B. Subcategory 1A would include pyrophoric gases (which were not addressed in the fifth edition of the “Purple Book” and were added to the Hazardous Products Regulations as a non-GHS class) as well as chemically unstable gases. Subcategory 1B would include flammable gases that are not pyrophoric or chemically unstable but have a lower flammability hazard than those of Subcategory 1A.
- Aerosols were previously only classified as “Flammable Aerosols,” with categories of very and less flammable. The amendment will add a third category and classification criteria for non-flammable aerosols.
- “Chemicals Under Pressure” (a distinct class separate from “Gases Under Pressure”) will be created. This, interestingly, is from the eighth revised edition of the Purple Book but was considered important enough to be added to the amendments referencing the seventh edition.
- Clarifications have been added to assist in classifying and identifying substances that evolve toxic gases on contact with water but are not otherwise toxic in their original dry condition.
- For Corrosives/Irritants to Skin and Serious Eye Damage/Irritant to Eyes substances classified based on ingredients without testing, the system will now authorize classification into subcategories based on the subcategories of the ingredients.
- An additional criterion was established for classification in Specific Target Organ Toxicity – Single Exposure, Category 3.
- Other classes will have minor updates to criteria to match UN standards or clarify areas that have caused interpretation problems.
Even if the classification changes do not affect your product, there are changes to the format of the Safety Data Sheet (SDS). Section 9, Physical Properties, such as dividing “Appearance “into two fields, “Physical state” and “Color,” and adding “particle characteristics.”
There is expected to be a 2-year transition period.
Stay tuned for the official announcement and contact ICC early to get your SDS update requests in a queue.
ICC Compliance Center has a team of full-time Regulatory Experts who have years of experience and are certified/recognized in their field of expertise. Contact us about authoring, reformatting, updating, and translating your SDSs. Ask us your tough questions by calling 855.734.5469 or send us an email, we’re happy to help.
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