Get Ready to Revise Your SDSs and Product Labels for OSHA’s Updated GHS Hazard Communication Standard

February 08, 2021
First established in 1983, OSHA’s Hazard Communication Standard provides a standardized approach to workplace hazard communications associated with exposure to hazardous chemicals. OSHA updated the standard in 2012 to align with the third revision of the United Nations’ Globally Harmonized System of Classification and Labelling of Chemicals (GHS) to provide a common approach to classifying chemicals and communicating hazard information. Within the next few days OSHA will publish a proposed rule to update the agency’s Hazard Communication Standard (HCS) to align with the seventh revision of the GHS. Many other countries have adopted the seventh revision, so this update will eliminate many of the inconsistencies between US and international requirements.
OSHA expects the HCS update will increase worker protections and reduce the incidence of chemical-related occupational illnesses and injuries by further improving the information on the labels and Safety Data Sheets for hazardous chemicals. Proposed modifications will also address issues since implementation of the 2012 standard and improve alignment with other US federal agencies and Canada.
OSHA has preliminarily determined that the proposed modifications would enhance the effectiveness of the standard by improving dissemination of hazard information, so employees are more appropriately apprised of exposure to chemical hazards in the workplace. Some of the key changes include:
  • Adoption of consensus standards for determining key properties of regulated substances, such as flammability, solid/liquid, explosives, gases, and oxidizers.
  • Revised or new definitions of gas, liquid, solid, combustible dusts, nuisance particulates, exposure/exposed, physician or other licensed health care professional, and bulk shipments.
  • Transfer the pyrophoric gas hazard to be incorporated by the flammable gas hazard.
  • New hazard classes for aerosols and desensitized explosives.
  • Expand hazard classification to include not only normal conditions but also use and foreseeable emergencies.
  • Expand hazard classification to include any hazards associated with a change in the chemical’s physical form or resulting from a reaction with other chemicals under normal conditions of use. This will be reflected in Section 2 of the SDS, as discussed below.
  • Require labels to include the date a chemical is released for shipment.
  • Specify that labels for bulk shipments of hazardous chemicals are either on the immediate container or may be transmitted with shipping papers, bills of lading, or other technological or electronic means so that the information is immediately available in print to workers on the receiving end of the shipment.
  • Delete the exclusion that did not require containers marked with DOT labels to bear OSHA hazard pictograms.
  • Revise requirements for relabeling existing stocks of products when new hazard information is discovered after those products were labeled, but not yet shipped.
  • New and revised requirements, and some exclusions for labeling small containers.
  • Allow SDSs to be stored, rather than designed, in a way to cover groups of hazardous chemicals in a work area
  • Allow manufacturers to claim chemical ingredient concentration ranges as trade secret information, however the concentrations would be required to be stated within specific ranges (such as 0.1 – 1%, 1 – 5%, etc.) as they are currently required in Canada.
  • Require impurities and additives to be considered in hazard classification
  • Add or make revisions to how the following health and physical hazards are determined: acute toxicity, skin corrosion/irritation, serious eye damage/irritation, germ cell mutagenicity, reproductive toxicity, specific target organ toxicity, respiratory sensitization, skin sensitization, carcinogenicity, aspiration hazard, explosives, flammable gases, flammable and non-flammable aerosols, gases under pressure, flammable liquids and solids, desensitized explosives, oxidizing solids, as well as new hazard categories for some of these hazards.
  • For materials with unknown toxicity, require labels to identify the mode(s) of exposure with unknown toxicity.
  • A large number of significant changes in hazard statements and precautionary statements.
  • An update of the hazard label elements for several hazard classes and categories.
  • Require a US-based address and phone number in Section 1 of the SDS.
  • Require Section 2 of the SDS to include hazards identified under normal conditions of use that result from a change in physical form chemical reaction during use or processing.
  • Require Section 3 of the SDS to identify the CAS number or other identifier for additives that contribute to the hazards of the material.
  • Require the applicable OSHA PEL, ACGIH TLV or any other exposure limit used or recommend by the SDS preparer to be included in Section 8 of the SDS. The SDS must also include a range of exposure limits whenever a range is used or recommended by the chemical manufacturer, importer, or employer preparing the SDS.
  • In SDS Section 9, replace “appearance” with “physical state” and “color,” eliminate “odor threshold” and “evaporation rate” as separate required properties; add the term “kinematic” to the property “viscosity,” and add “particle characteristics” as a new physical property.
  • In SDS Section 10, clarify that “stability and reactivity” includes hazardous reactions associated with foreseeable emergencies.
  • In SDS Section 11, when specific chemical data or information is not available, SDS preparers must indicate if alternative information is used and the method used to derive the information (e.g., where the preparer is using information from a class of chemicals rather than the exact chemical in question and using structure activity relationships (SAR) to derive the toxicological information).
OSHA has proposed to implement the revised provisions over a two-year phase-in period. The revisions become effective 60 days after the publication date in the Federal Register. Chemical manufacturers, importers, and distributors evaluating substances comply with all modified provisions of the HCS will be required to comply no later than one year after the effective date. OSHA also proposed that chemical manufacturers, importers, and distributors evaluating mixtures comply with all modified provisions no later than two years after the effective date.
If you need assistance in determining how your products will be impacted by the updated hazard communication standard, or if you would like your SDSs and labels updated, contact Environmental Resource Center for assistance at
Upcoming Training
To help you get the training you need, Environmental Resource Center has a number of upcoming live webcast training courses. Stay in compliance and learn the latest regulations from the comfort of your office or home. You’ll receive the same benefits as our seminar attendees including expert instruction, comprehensive course materials, one year of access to our AnswerlineTM service, course certificate, and a personalized user portal on Environmental Resource Center’s website.
Environmental Resource Center training is the best way to learn about the environmental, safety, and hazardous materials transportation requirements that apply to your site. Learn from the experts and get your site-specific questions answered at these sessions this week:
Permanent Rule Addressing COVID-19 in all Workplaces Proposed in Oregon
Seeking to extend protections for workers against the coronavirus disease, Oregon OSHA is proposing a permanent rule that largely maintains – with some improvements – the risk-reducing measures required by the current temporary emergency rule. It would replace the temporary rule, which expires on May 4.
The proposed permanent rule will receive virtual public hearings later this month and in early March. Although the rule must be adopted as a permanent rule because the law does not allow a temporary rule to be extended, Oregon OSHA expects to repeal the permanent rule once it is no longer needed to address the coronavirus pandemic.
“The public health emergency triggered by COVID-19 remains a significant concern in Oregon – as we know, we have not yet defeated this disease and we clearly will not have done so by the time the temporary rule expires. As a result, it is critically important that we carry forward measures that we know are effective at combating the spread of this disease and reducing risks in the workplace," said Michael Wood, administrator for Oregon OSHA. “Failure to do so will undoubtedly leave workers far less protected and leave employers with far less clarity and certainty in terms of what is expected of them."
As with the temporary rule, which took effect Nov. 16, 2020, the proposed permanent rule maintains such requirements as physical distancing; use of face coverings; regular sanitation; employee notification and training; maximization and maintenance of existing ventilation systems; and formal exposure risk assessment and infection control planning. The proposed permanent rule would allow employers to rely upon the risk assessments, infection control plans, and infection control training already completed.
However, the permanent rule would add measures and strengthen provisions in certain areas. Those proposed changes include:
  • Requiring employers to consider alternatives to transporting multiple people in a single vehicle, although such transportation would not be prohibited.
  • Slightly modifying the ventilation measures so that employers with more than 10 employees – and that have existing ventilation systems – must certify in writing that they are running their systems in line with current requirements. The proposed rule does not require the purchase or installation of new ventilation systems.
  • Requiring employers to provide written notification to employees of their rights to return to work when employees must quarantine.
  • Requiring employers to cooperate with public health authorities that ask to arrange for vaccination in the workplace. This proposed requirement is similar to the temporary rule's provision mandating cooperation with public health officials if COVID-19 testing in the workplace is necessary.
  • Requiring health care employers to provide respirators to employees working with known or suspected COVID-19-positive patients unless they demonstrate there is a genuine shortage that they are working to resolve.
The proposed permanent rule also strengthens the language discouraging the use of face shields, which have been shown to be less effective than masks or facial coverings although such devices would remain an option for source control.
The proposed permanent rule was developed in consultation with two rulemaking advisory committees assembled for the purpose. It largely reflects the provisions of the current temporary rule, which itself was based to a large extent on the guidance produced by the Oregon Health Authority and enforced in the workplace by Oregon OSHA. The temporary rule was developed following an extensive stakeholder and public comment process last summer, which is not normally the case when temporary rules are developed.
Oregon OSHA encourages a careful reading of the proposed permanent rule. Virtual public hearings will be held at 10 a.m. on Feb. 23 and Feb. 26, and at 5 p.m. on March 3 and March 4. Details on how to sign up for the hearings – as well as other options for commenting on the proposed rule – are now available. The comment period will close on April 2.
Title V Facilities' Air Emissions Reports Due March 31 in Iowa
Facilities subject to Title V of the federal Clean Air Act must submit their emissions inventories for 2020 to the Iowa Department of Natural Resources (DNR) Air Quality Bureau by March 31, 2021.
To increase efficiency and simplify the emissions reporting requirement, DNR requires you to report the 2020 emissions electronically using the State and Local Emissions Inventory System (SLEIS).
For assistance regarding Emissions Inventory or Fee Payment (due July 1, 2021), please contact Jeremy Arndt at 515-725-9511 or For assistance regarding SLEIS, please contact Nick Page at 515-725-9544 or
If your initial Title V permit was issued prior to Jan. 1, 2021, the Annual Compliance Certification and the Semi-Annual Monitoring Report are also due March 31, 2021. Contact Mark Fields at (515) 725-9526 or if you have questions about these reports. For additional information on all Title V reporting requirements, please check the informational letter DNR sent to Title V facilities.
Prisons and Hospitals Cited for COVID Violations
Cal/OSHA has cited multiple employers for not protecting workers from COVID-19 during inspections in various industries throughout the state. Violations were identified in industries including health care, restaurant, retail, fitness centers, correctional institutions and more. Cal/OSHA opened the inspections after learning of COVID-19 fatalities and illnesses, after receiving complaints and during targeted inspections.
The full list of employers cited for COVID-19 violations is posted on Cal/OSHA’s website. Some of the employers cited for COVID-19 violations include:
Employer Name
Worksite Location
San Quentin State Prison
Correctional Institutions
San Quentin
Avenal State Prison
Correctional Institutions
BSF Fitness II LLC
Fitness and Recreational Sports Centers
Kaiser Permanente San Leandro
General Medical and Surgical Hospitals
San Leandro
Kaiser Permanente Antioch Medical Center
General Medical and Surgical Hospitals
Kaiser Permanente Walnut Creek Medical Center
General Medical and Surgical Hospitals
Walnut Creek
Mills-Peninsula Medical Center
General Medical and Surgical Hospitals
NorthBay Medical Center
General Medical and Surgical Hospitals
Fremont Healthcare Center
Nursing Care Facilities
Sunray Healthcare Center
Nursing Care Facilities
Los Angeles
San Miguel Villa
Nursing Care Facilities
Coldwater Care Center LLC dba Sherman Village Healthcare Center
Nursing Care Facilities
Valley Village
Cardenas Market
Grocery Stores
Grimmway Enterprises, Inc.
Carter's Children's Wear
Children's Clothing Stores
Inspections at the San Quentin and Avenal state prisons occurred after reports of hospitalizations of staff following outbreaks at the institutions. Cal/OSHA determined that San Quentin staff were not provided adequate training or equipment for working with COVID-19 infected individuals, and employees who had been exposed to COVID-19 positive inmates were not provided proper medical services, including testing, contact tracing and referrals to physicians or other licensed health care professionals. Cal/OSHA issued citations for four willful-serious, five serious, one regulatory and four general category violations, including the employer’s failure to institute an effective aerosol transmissible diseases (ATD) control exposure plan. Avenal State Prison was cited for three serious violations after Cal/OSHA found it failed to maintain an effective written ATD program including site-specific instruction, had an inadequate written respiratory protection plan, and failed to implement and/or enforce work practice controls to minimize exposure to COVID-19 amongst employees.
Cal/OSHA cited the Ventura-based fitness center BSF Fitness for one willful-serious, two serious and six general category violations following a COVID-19 complaint-initiated inspection opened last July, after Cal/OSHA received a report that the employer was not enforcing face covering use and physical distancing in its gym. Cal/OSHA determined the employer failed to effectively establish, implement and maintain procedures to correct unhealthy conditions related to COVID-19 that affected its employees, including its failure to enforce face covering use and physical distancing for COVID-19 prevention.
Cal/OSHA opened accident inspections following reports of serious COVID-19 related illnesses at the Kaiser Permanente medical centers in San Leandro, Antioch and Walnut Creek, and Burlingame-based Mills-Peninsula Medical Center; and opened a complaint-initiated inspection at Fairfield-based NorthBay Medical Center. The facilities were cited for serious and regulatory violations after Cal/OSHA found multiple deficiencies in their ATD and respiratory protection programs, and that the employers failed to immediately report COVID-19 related serious illnesses.
Also cited for multiple serious violations due to ATD deficiencies that Cal/OSHA determined exposed their employees to COVID-19 infection were four skilled nursing centers: Sunray Healthcare Center and Sherman Village Healthcare Center (both located in the Los Angeles area), Fremont Healthcare Center in Fremont, and San Miguel Villa in Concord. Fremont Healthcare Center and San Miguel Villa were also cited for a regulatory violation after Cal/OSHA found they failed to immediately report serious illnesses suffered by employees who were hospitalized with complications from COVID-19.
Cal/OSHA cited Cardenas Market in Oakland for multiple violations including three serious-category violations following an inspection opened after learning from media coverage of an outbreak where seventeen workers tested positive for COVID-19 last May, including one worker who was hospitalized due to complications from the infection. Cal/OSHA determined that Cardenas Market failed to adequately address the potential outbreak of the coronavirus among workers by implementing preventative measures. Cardenas Market did not initially implement or require face coverings or masks, physical distancing or training of workers on coronavirus hazards. Cardenas Market also failed to immediately report a COVID-19 related serious illness.
Grimmway Enterprises, Inc. was cited for multiple violations including two serious-category violations, following a fatality-initiated inspection when an employee was hospitalized and died from COVID-19 after working at a carrot field in Holtsville. Cal/OSHA found that the employer did not implement methods or procedures to correct unhealthy conditions or work practices relating to COVID-19 that affected its employees working outdoors, and the employer failed to provide its employees effective training and instruction on the hazards of COVID-19.
Cal/OSHA also cited Carter's Children's Wear in Gilroy for one regulatory and one serious citation following a COVID-19 accident inspection. Cal/OSHA found that the employer failed to immediately report a COVID-19 related serious illness and failed to establish, implement and maintain an effective Injury Illness Prevention Program.
To assist employers with understanding their requirements to protect workers from COVID-19, Cal/OSHA has created guidance and resources, including a model written COVID-19 Prevention Program, COVID-19 information page and free webinars for certain industries from Cal/OSHA Consultation Services.
New Mexico Radioactive Material Licensing Compliance Initiative Focused on Oil and Natural Gas Industry
The New Mexico Environment Department (NMED) launched a compliance initiative to ensure oil and natural gas companies are properly licensed and in compliance with rules governing the management of regulated Natural Occurring Radioactive Materials (NORM).
Under regulations adopted by the Environmental Improvement Board more than two decades ago, oil and natural gas operators must obtain a license through NMED if their activities alter, concentrate or cause potential human exposure to NORM at certain levels. These activities may consist of extraction, transfer, transport, storage, or disposal of materials. NMED currently regulates two NORM licensees.
The Department’s regulations specifically address NORM found in equipment from oil, gas, soil, produced water, sludges, scale deposits in pipes, tanks, and equipment from gas processing, fractionation, and dry gas distribution above certain levels. For example, pipes transporting fluids brought up during operations may accumulate scale over time. If this scale contains NORM at certain concentrations, a license may be required. Licenses require entities to provide details as to how the material is managed, handled, and disposed of to ensure public health and the environment are protected.
NMED is issuing letters to approximately 20 oil and gas companies that operate a combined 39,000 wells in New Mexico. Any company receiving such a letter must respond to NMED within 60 days describing their compliance status. Failure to comply with the requirements outlined in the letter may result in civil penalties of up to $15,000 per day.
Over the next few months, NMED will determine the extent of compliance or non-compliance with the rules by the oil and natural gas industry and take appropriate enforcement action if warranted.
Operating without a license is a violation of state law. It may result in enforcement proceedings in accordance with NMSA 1978, Section 74-3-11.1, including the following: a compliance order with civil penalties of up to $15,000 per day for each violation or (a civil action in district court for appropriate relief, including injunctive relief.
More information on NORM is available here.
Load-Reducing Backpack Powers Electronics By Harvesting Energy from Walking
Hikers, soldiers and school children all know the burden of a heavy backpack. But now, researchers have developed a prototype that not only makes loads feel about 20% lighter, but also harvests energy from human movements to power small electronics. The new backpack, reported in ACS Nano, could be especially useful for athletes, explorers and disaster rescuers who work in remote areas without electricity, the researchers say.
Backpacks are widely used in everyday life for the hands-free carrying of loads. Over time, however, walking or running with a heavy sack can cause back and neck pain. Also, backpackers in wilderness areas (or even those in cities who don’t have ready access to a charger) might wish for a bag that could harvest the mechanical energy of walking to power portable electronics or health-monitoring sensors. Previously, researchers have used triboelectric nanogenerators (TENG) –– small devices that convert mechanical energy into electricity –– to make energy-harvesting backpacks, but those bags had relatively low power outputs and they didn’t provide added benefits, such as load lightening or shock absorption. Zhong Lin Wang, Jia Cheng and colleagues wanted to design a prototype that overcame these limitations.
To save labor and absorb shock, the researchers incorporated into the backpack two elastomers that stretched and shrank, keeping the bag steady as the wearer walked. This resulted in about a 20% reduced force on the wearer. Meanwhile, movement between the frame of the backpack and its load during walking drove a TENG to convert mechanical energy into electricity, with 14% efficiency. The researchers showed that the bag could power LEDs, an electric watch and fluorescent tubes. Once some challenges, such as improving the energy conversion efficiency, are overcome, the backpack has promising potential as a power source for small-scale wearable and portable electronics, GPSs and health care sensors, the researchers say.
The authors acknowledges funding from the National Natural Science Foundation of China, the National Science and Technology Major Project of China, the National Key Research and Development Program of China and the Tsinghua University Initiative Scientific Research Program.
Proposed Changes to Nebraska Title 124 Onsite Wastewater Regulations
The Nebraska Department of Environment and Energy will present Proposed Changes to Title 124, Rules and Regulations for the Design, Operation and Maintenance of Onsite Wastewater Treatment Systems webinar on Friday, March 5, 2021, at 9 a.m. This webinar is intended for installers, inspectors, pumpers and engineers of onsite wastewater systems, and homeowners or industrial facilities who use an onsite wastewater system for treatment and disposal of wastewater. The free seminar is open to the public.
The presentation will give an overview of proposed revisions to Nebraska Administrative Code Title 124 – Rules and Regulations for the Design, Operation and Maintenance of Onsite Wastewater Treatment Systems. The proposed revisions implement Executive Order No. 17-04 on Regulatory Reform, streamline and clarify existing provisions, and adopt changes to state and federal law.
This event also provides public outreach on a preliminary draft of Title 124. Once finalized, the regulations will be placed on public notice for a hearing before the Environmental Quality Council.
Regulatory streamlining and language modernization revisions have been proposed for all chapters. The most notable proposed change is moving design requirements out of regulation and into general permits. For example, initially there would be a general permit for each (1) traditional systems, (2) lagoons, (3) holding tanks and (4) permitted systems, and additional permits for other types of systems could be added at a later date. This has been done in other regulatory programs and enables the Agency to more quickly adapt to changes in the industry and emerging technologies by issuing general permits that are subject to public review and comment.
To register:
  1. Go to NDEE Proposed T124 Changes to Onsite Wastewater Regulations
  2. Click "Register.”
  3. On the registration form, enter your information and then click "Submit.”
Once registered, you will receive a confirmation email message with instructions on how to join the event.
Court Strikes Down Trump EPA’s Secret Science Rule
A federal court struck down an 11th hour Trump Environmental Protection Agency that would have severely restricted the use of peer-reviewed science in setting health-based limits on pollution and toxic chemicals.
The Trump EPA published its final “censored science” rule on January 6, 2021. The Environmental Defense Fund, Montana Information Center and Citizens for Clean Energy sued to block its implementation and the U.S. District Court for the District of Montana Great Falls Division vacated that rule on February 1, 2021.
Free Amazon HD 10 Tablet with RCRA and DOT Training
Annual training is required by 40 CFR 262.17(a)(7). Learn how to complete EPA’s new electronic hazardous waste manifest, and the more than 60 changes in EPA’s new Hazardous Waste Generator Improvements Rule. Environmental Resource Center’s Hazardous Waste Management: The Complete Course is available via live webcasts. If you plan to also attend DOT Hazardous Materials Training: The Complete Course, call 800-537-2372 to find out how you can get your course materials on an Amazon Fire HD 10 tablet at no extra charge.
Job Openings at Environmental Resource Center
Environmental Resource Center has openings for EHS consultants and trainers. If you are looking for a new challenge, send your resume and salary requirements to Brian Karnofsky at
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