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OSHA’s New Aerosol Classification

OSHA’s New Aerosol Classification

Everyone is discovering the news that OSHA has updated their chemical regulations to embrace version 7 of GHS. This is good news in that it now aligns with other countries around the world, especially Canada and Europe. There were several changes implemented, such as small packaging rules, how to manage trade secrets, updates to existing classifications, new classifications, and so on. One big change is the new way to classify aerosols. This was a big jump compared to the previous version. Aerosols are considered flammable if any component has flammable ingredients. However, there is a distinction in the categories for an Aerosol classification.

Hazcom 2012 (OLD) vs Hazcom 2024 (New)

Under the old regulations Flammable aerosols were associated with Gases under pressure. This was aligned with version 3 of GHS. Since then, OSHA has determined that this representation of classification didn’t represent the full extent of the varying hazards associated with aerosols. To compensate OSHA has adopted version 7 and has included a new hazard category under the Aerosols classification. There is now a category 3 that simple states “Pressurized container; may burst if heated”, with no pictogram. This is intended to extend the classification to include a product that is in aerosol form and contains no flammable components. This is a major change for safety data sheets and labels. Whereas before if a product in an aerosol form it was solely considered “Gas under pressure” with a Gas cylinder pictogram. Now it can be classified as “Pressurized container; may burst if heated” with no pictogram.

But it is not that simple. There are new rules and categories to consider when properly classifying your product. The data used to determine the classification for safety data sheets and labels will need to be reassessed for each product to determine the type of classification your product will fall into. The good news is that OSHA has created a transitional period to ensure your product can align with the new OSHA hazard communication regulations. Manufacturers of substances have until January 19, 2026, to update the product labeling and safety data sheets. Manufacturers of mixtures have until January 19, 2027, to make these similar changes to their products and labels.

Will these changes be effective. I believe they will. This would give consumers or industry a better understanding of the hazards related to the product. Whereas before you were limited by the type of classification to use, now there are more options. It now focuses not just on the chemical itself but also the form the product is in.

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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Rick Mastroianni

Rick Mastroianni joined the ICC Regulatory Experts team in 2022. He has many years of experience as an SDS Author, including preparing regulatory-compliant label text for product applications. His regulatory knowledge includes OSHA, WHMIS, CCCR, and EU CLP. Currently, his primary focus with our Regulatory Experts team is the creation of safety data sheets and labels for the different jurisdictions in North America and Europe.

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