By Phil Molé, MPH

HazCom 2024 affects all users of hazardous chemicals throughout the chemical supply chain. Chemical manufacturers have work to do as the compliance clock keeps ticking. So do importers and distributors. And as updated hazard information makes its way downstream, employers who use hazardous chemicals affected by the final rule have many responsibilities of their own.

For employers, receiving an updated safety data sheet (SDS) or shipped container label isn’t the end of the process. It’s where another important part of the process begins.

You need to be able to take updated hazard information and put it to work throughout your Hazard Communication (HazCom) program. That means managing updated SDSs, making current information accessible to employees, keeping workplace container labels aligned with updated shipped container labels, updating your written HazCom plan as needed, and making sure employees receive appropriate training.

In other words, HazCom 2024 compliance isn’t just about having updated information. It’s about being ready to use it.

HazCom 2024 Creates Responsibilities Across the Chemical Supply Chain

The changes introduced by OSHA’s 2024 final rule updating the HazCom Standard, known as HazCom 2024, don’t happen everywhere at once.

To understand why, it’s important to have good working knowledge of how HazCom has changed because of the 2024 final rule.

A Refresher on the 2024 HazCom Final Rule

Here are some of the major changes under HazCom 2024:

Hazard Classifications

HazCom 2024 expands the aerosols hazard class to include non-flammable aerosols, now categorized under a new Category 3. This adjustment aims to enhance user understanding of the specific hazards associated with various aerosols and the ways that container failure mechanisms differ from those of gases under pressure, known as gas cylinders, the category that many aerosols previously found themselves in.

The rule also adds a category for chemicals under pressure, following and adopting the categories of chemicals under pressure from GHS Revision 8. The new classification includes liquids or solids pressurized with gas, which improves hazard communication clarity.

Another critical update is the addition of desensitized explosives as a new hazard class. These products, stabilized with a wetting or stabilizing agent, are safer to handle than ordinary explosives as long as the stabilizing agent is in place and effective. The classification system now includes four categories based on corrected burning rates, offering detailed stability and hazard information to users, including how to confirm that stabilizing agents are in place.

The final rule also modifies the classification of flammable gases, splitting Category 1 into subcategories 1A and 1B, better distinguishing hazards associated with different flammable gases. Pyrophoric and chemically unstable gases fall under Category 1A, emphasizing the need for specific hazard and precautionary statements for safe handling.

Labeling Requirement Changes

HazCom 2024 introduces new allowances for small and very small containers. For small containers (up to 100 milliliters), manufacturers can use abbreviated label information if the full shipped container label information is on the outer packaging.

For very small containers (up to 3 milliliters), only the product identifier is required on the container, if the manufacturer argues that a label would interfere with the normal use of the container. Once again, a chemical manufacturer who takes advantage of this allowance would need to provide full shipped container information on the outer packaging.

Both manufacturers of small and very small containers also need to include a statement on the outer packaging telling users to replace the small and very small containers in the outer packaging when the containers are not in use.

These allowances and requirements balance the need for hazard communication with practical labeling considerations, ensuring essential safety information remains accessible.

Other HazCom 2024 Updates

Bulk shipments: OSHA has clarified that the term “bulk shipment” refers to any hazardous chemical transported in a container that also serves as the mode of transportation, such as tanker trucks or railcars. This update aligns with a 2016 joint memorandum with the Department of Transportation (DOT).

Chemicals Released for Shipment: HazCom 2024 relieves chemical manufacturers of the need to relabel “chemicals released for shipment” if they learn of new hazard information. Yet they still would need to provide an updated shipped container label with the shipment.

Intrinsic Hazards and Downstream Uses: HazCom 2024 requires chemical manufacturers to consider intrinsic hazards in chemical classifications, including those related to chemical reactions or changes in form from known or reasonably anticipated downstream uses of the chemical, and to include that information in Section 2 of the SDS. This ensures that end users receive detailed and accurate hazard information, facilitating safe handling of chemicals.

Confidential Business Information (CBI): OSHA has also expanded trade secret provisions, enabling manufacturers to withhold concentration ranges as trade secrets, provided they choose from a prescribed list. This adjustment aligns better with Canadian regulations and offers manufacturers greater flexibility, while maintaining transparency and safety. Previously, OSHA only allowed chemical manufacturers to withhold the specific concentration as CBI.

Information Requirements for SDSs: HazCom 2024 updates information required in several sections of the SDS, including Section 9. This includes, for example, adding particle size information to the list of physical characteristics.

HazCom 2024 Changes Ripple Through the Supply Chain

Obviously, the HazCom 2024 changes start upstream, with chemical manufacturers evaluating the chemicals they produce and updating hazard information as required by the final rule. For example, changes to chemical classifications may result in manufacturers needing to reclassify some of their products and update associated hazard information. Further updates to SDS information requirements and the need to consider reasonably anticipated downstream uses during hazard evaluation will necessitate reauthoring of many SDSs.

Updated SDSs and shipped container labels need to make their way through the supply chain. Eventually, those changes reach employer worksites like yours.

If hazardous chemicals affected by HazCom 2024 are present in your workplace, you’ll need to incorporate applicable updated hazard information into your workplace HazCom management. And because those updates originate upstream, the timing of your work may depend in part on when you receive new information from your suppliers.

That makes HazCom 2024 a chemical information management challenge as much as a compliance challenge.

Once an updated SDS or label reaches you, how quickly can you identify what’s changed? And how easily can you put that new information to use?

Getting Updated Hazard Information Is Only the Beginning

For employers, HazCom compliance depends on more than collecting SDSs. Updated hazard information can affect multiple parts of your workplace HazCom program. Here’s what that can mean in practice.

1. Managing the Inflow of Updated SDSs

As manufacturers update their SDSs, new versions will begin replacing the versions you already have. You need a reliable way to manage that flow of information.

Which SDS is current? Has a supplier provided a new version? Which version should employees use? And how easily can you archive the SDS version that was replaced?

Those questions become increasingly important when you’re managing hazardous chemicals across a large workforce, multiple facilities, or an extensive chemical inventory.

A well-managed SDS library helps you maintain confidence that you’re working from current hazard information rather than outdated versions.

2. Making Updated SDSs Easy to Access

Keeping your SDS library current is one part of the job. Employees must also access the information they need in the workplace.

After all, hazard information can only help protect people when they can use it.

As updated SDSs arrive, employers need processes that make current information readily accessible rather than leaving employees to sort through old and new versions or wonder which information applies. Employees need access to SDSs at any time during their shift, with no barriers, and employers must also make sure they have a secondary/emergency access system if the primary one temporarily fails.

That connection between current information and easy access is an essential part of effective chemical management.

3. Keeping Workplace Container Labels Aligned with Updated Information

SDSs aren’t the only source of information that may change as HazCom 2024 updates move through the supply chain.

Employers must also be prepared to use updated shipped container label information as the basis for their workplace container labels, known as secondary container labels.

This illustrates an important point: SDS management and labeling aren’t isolated activities.

When hazard information changes, employers need to understand where that information is used throughout the workplace and make appropriate updates. The easier it is to connect current chemical information with your labeling processes, the easier it is to keep those processes aligned.

4. Updating Your Written HazCom Plan as Needed

Updated chemical information from your suppliers may also have implications for your written HazCom plan.

As applicable new hazard information becomes available, employers need to evaluate whether changes are needed and update their written program accordingly. Think of it as change management for your HazCom program.

You need to be able to receive new information, understand what has changed, determine where those changes matter, and make the appropriate updates. For example, you may need to update the Plan’s discussion of the chemical hazards present in the workplace to reflect new hazard classifications, including chemicals under pressure and desensitized explosives, and describe your methods for communicating these hazards to employees.

This level of coordination is difficult if chemical information is scattered across disconnected files, systems, or locations.

5. Making Sure Training Keeps Pace with New Information

Hazard communication ultimately needs to reach the people working with or around hazardous chemicals. In fact, that’s the whole reason OSHA developed the HazCom Standard in the first place.

That makes training a crucial part of managing HazCom 2024 changes.

Desensitized explosives offer a useful example. If desensitized explosives are present in your workplace, employees need to understand what they are and the hazards associated with them to ensure they can continue working safely with these products. Training should address the importance of ensuring that the stabilizing or wetting agents needed to maintain their desensitized state are present.

That’s information people need to understand and act on, not information that should simply sit inside an SDS.

Effective HazCom management depends on connecting chemical information with the people and processes that rely on it. Remember, OSHA’s standard for evaluating whether employers are meeting their training obligations is based on the “right to understand.” That is, you can’t just assign employees a HazCom module and assume that is sufficient. The training, like the HazCom plan, needs to be site-specific, and you need to evaluate whether employees have understood the training.

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Chemical Management Goes Beyond Compliance

Of course, meeting HazCom requirements matters. But good chemical management has never been just about checking a compliance box.

It’s about knowing which chemicals are in your workplace. Understanding their hazards. Maintaining reliable information about them. Making that information accessible to the people who need it. And having processes that can adapt when something changes.

HazCom 2024 puts that last point into sharp focus.

Chemical information isn’t static. Regulations change. Suppliers update SDSs and labels. Hazard information evolves. You may stop using some chemicals and start using others.

A resilient chemical management program needs to keep up.

Instead of treating each new SDS or regulatory change as a standalone administrative task, employers should think more broadly about whether their chemical management processes make it easy to absorb new information and act on it. You should evaluate how well you can tell when information has changed, how easily you can get the current version into employees’ hands, and whether they’re able to use that information to update your labeling, your written program, and your training.

The answers to these questions matter for compliance. But they also matter for your ability to proactively manage chemical risk.

Chemical Management Software Helps You Put Information to Work

Managing changing chemical information manually can become complicated quickly, especially when you’re responsible for large chemical inventories or multiple locations.

Chemical management software can help bring that information together.

Software makes it easier to keep SDSs and chemical information organized and current, manage updated SDSs as they arrive, give employees access to the information they need, and use current information to support other parts of workplace chemical management.

Technology should make those jobs easier, so EHS professionals can stay focused on what matters most: managing hazards and protecting people.

From HazCom 2024 Compliance to Stronger Chemical Management

To summarize, don’t make the mistake of thinking that HazCom 2024 won’t affect you or that its impact will be minimal.

HazCom 2024 changes begin upstream, but their effects eventually reach most workplaces and bring far-reaching obligations.

For employers, this means ensuring you’re getting revised SDSs and shipped container labels from your suppliers, and that you’re ready to use them to make relevant updates to your workplace hazard communication practices.

You’ll need to manage updated SDSs as they replace older versions, making sure that the current SDSs are accessible. You’ll also need to use updated shipped container labels as the basis for revised workplace container labels. Update your written HazCom plan as needed. And make sure your site-specific HazCom training addresses important new information available, including handling and storage information for desensitized explosives and methods that confirm the stabilizing agents are in place and still effective.

All of these are compliance responsibilities, but they are also the building blocks of good chemical management. Because keeping up with HazCom 2024 isn’t just about keeping up with changing information. It’s about making sure your chemical management program is built to keep up, too.

Looking For Additional Resources and Information?

Check out these HazCom resources, including:

As always, follow the VelocityEHS blog for the latest updates on EHS.

Partner with VelocityEHS to Move Beyond Compliance

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You can maintain an up-to-date SDS library and provide access from anywhere, but that’s just the beginning. From support for workplace container labeling to container-level tracking and inventory mapping to our machine language powered chemical ingredient indexing service, including the AI PFAS Indicator, you’ll finally have all the governance you need in one place.

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