In 2012, the United States officially adopted GHS standards when OSHA updated their Hazard Communication Standard to align with the Globally Harmonized System of Classification and Labeling of Chemicals. On May 20, 2024 OSHA issued an update on the Hazard Communication Standard to align with the seventh revision of GHS Standards. The US Department of Labor maintains that any business where employees “could be exposed to hazardous chemicals” is required to comply with OSHA’s Hazard Communication Standard. Compliance labels are those that meet the GHS standard and both identify and communicate information about hazardous chemicals.
What is GHS?
The Globally Harmonized System of the Classification and Labeling of Chemicals (or, GHS) was created in 1992 by the United Nations in order to create a uniform system of identifying, labeling, and communicating chemical hazards. By maintaining compliance with the standard, companies throughout the chemical supply chain made it easier for people in close contact with the chemicals to identify dangerous substances. The content and symbols used on a GHS label are standardized and recognizable, regardless of country.
What is the Hazard Communication Standard?
The Hazard Communication Standard (HCS) was created by OSHA with similar goals as GHS - provide a standard for communicating hazards associated with exposure to certain chemicals. Chemical manufacturers and importers in the United States are required to classify the hazards of chemicals and label them appropriately. All employers with hazardous chemicals in their workplaces must ensure that the chemicals are labeled and that employees have safety data sheets accessible in order to maintain compliance with HCS. This includes properly labeling secondary packaging if a chemical has been dispensed from a bulk container into a second package/container.
While the original implementation of HCS was well intentioned, the practical use of it had issues. Companies were required to provide hazard information, but how that information was provided was determined by individual companies. In addition, in order to comply with international and US regulations, chemicals were often relabeled.
The final rule change to HCS to adopt GHS’ seventh revision is meant to fix these common issues and align the US with globally recognized standards.
HCS Label Requirements
In order to maintain compliance with HCS, compliance labels must include:
- Name and manufacturer information.
- Signal Words to communicate the level of hazard. There are two signal words, “Danger” which conveys the most severe hazard, and “Warning” which indicates a less severe hazard.
- Pictograms that convey the type of hazard. There are 9 available and recognized pictograms that communicate health, physical and/or environmental hazards.
- Precautionary statements that provide general, preventative, response, storage, and disposal information
Changes to HCS Label Compliance
In February 2021, OSHA proposed changes to the HCS that would align it with the seventh revision of GHS. The final rule was published on May 20, 2024 and took effect on July 19, 2024. In order to maintain compliance with HCS, companies must implement the changes by 2026.
The changes are meant to streamline compliance labels, improve worker safety, incorporate new hazards, and facilitate international trade. You can review OSHA's official amendments on their website. Listed below are a few of the changes made:
- Small packages, including 3mL and 100mL containers, have special labeling provisions
- Concentration ranges are required when exact concentration percentages are claimed as trade secrets
- Revisions to health hazard definitions and classes, including skin corrosion, flammable gasses, desensitized explosives, and aerosols
- Clarification on which hazards must be listed on a label versus an SDS
These changes may require updates to your compliance labels. GMP Labeling is a leader in regulatory labeling and product identification. We have a variety of stock labels purpose made for compliance labeling in regards to HCS and can also custom print a label for your specific need.
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