Updates to OSHA's HCS
The UN describes the GHS as a “living document.” Officials and regulators regularly meet to update the GHS to reflect how our understanding of hazards can change over time. When OSHA originally adapted their standards to the GHS, they adopted the 3rd revised edition. There have been a number of significant revisions since 2012, when OSHA adopted the 3rd revised edition of the GHS, and the most current GHS is the eighth revision.
OSHA has been reporting for several years that the HCS would be updated to reflect changes in the GHS. In early February 2021 OSHA issued proposed rules to update the HCS to align with the seventh revision of GHS (published in 2017). The proposed regulatory update is being issued as the United States’ major international trading partners, including Canada, Australia, New Zealand, and those in Europe, similarly prepare to align their own hazard communications rules with the seventh version of the GHS.
Among these proposed rules are new and revised hazard classifications, revised provisions for updating labels, and new labeling provisions for small containers. Comments on the proposed revisions are due by April 19, 2021 but once OSHA publishes the final rule, most labels will need to be revised.
This means that your current GHS/OSHA label customers will need new labels (as well as printers and ribbons). And if you’re looking for a new market to target, hazardous product manufacturers, importers and distributors in the US will all also need to update and replace their labels.