At the request of stakeholders, OSHA has extended the comment period on its proposed Hazard Communication Standard (HCS) update. Here’s what you need to know, direct from three OSHA staffers.
This update was presented by Janet Carter and Deana Holmes, both health scientists, and Jennifer Lawless, an industrial hygienist, all with OSHA’s Standards Directorate, at the Voluntary Protection Programs Participants’ Association’s “Next Level Safety” virtual conference.
After issuing a Notice of Proposed Rulemaking (NPRM) on Feb. 16, 2021, OSHA opened a comment period which initially was to end April 19, 2021.
The new deadline for comments is May 19, 2021.
Carter said there’s also been a request for hearings. If they’re held, they’ll be announced via the Federal Register. If a hearing is held, the comment period will be extended again.
The final rule will be based on feedback received via the comments, according to Carter.
She said the framework of HCS will remain the same. Updates will occur to things like definitions, Safety Data Sheets (SDSs) and hazard classes.
The update will align OSHA’s HCS with Revision 7 of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS).
Carter says HCS is a living document, with revisions based on feedback from stakeholders and advancements in science.
The revisions will:
- provide clarification of existing requirements
- incorporate new hazard classes and categories
- streamline precautionary statements, and
- facilitate international business through increased alignment.
Now, here are some of the nitty gritty details.
In the alignment of HCS with GHS Revision 7:
- revisions will be made to health hazard definitions
- updates will occur to skin corrosion/irritation and serious eye damage/irritation chapters
- the flammable gases categories will be expanded
- a new chapter on desensitized explosives will be added
- a category of aerosols will be added
- some label elements will changes, including updated hazards, guidance and precautionary statements, and
- there will be updates to SDS sections 9 and 11.
Holmes noted some labeling changes are a result of stakeholder comments after OSHA’s most recent HCS revision in 2012.
Labeling changes will address relabeling chemicals already released for shipment and what has to be on smaller labels.
Lawless says pyrophoric gases will now be directly addressed in HCS.
Some changes also involve alignment with Department of Transportation and EPA requirements.
What do you like?
Like what you see in the proposal?
Carter says it’s equally important to let OSHA know about that, as it is to speak up about any concerns.
You can submit comments here.
You can read the proposal here.