This document summarizes the key changes to the OSHA Hazard Communication Standard (HCS) to align it with the United Nations' Globally Harmonized System of Classification and Labeling of Chemicals (GHS). Some of the major changes include revising definitions, adding new definitions, revising criteria for classifying health and physical hazards, requiring new labeling elements, standardizing the format and order of information on safety data sheets, and updating training requirements. The changes are aimed at improving safety by ensuring hazards of all chemicals are evaluated and communicated in a consistent, globally-understandable manner.

1. Hazard Communication
Facts About GHS Compliance
April - 2012

2. OSHA 1910.1200 Standard
Several states enacted their own ―Right to
Know‖ law
Chemical manufacturers wanted one
uniform law vs. various state laws
1910.1200 Ordered by Congress -1985
Global Harmonization Standard (GHS)
added in 2012

3. Overview
Purpose
Definitions
GHS Changes
Pictograms

4. Purpose
To ensure that the hazards of all chemicals
produced or imported are evaluated, and that
information concerning their hazards are
transmitted to employers and employees.
Accomplished with:
- container labeling
- material safety data sheets
- employee training

5. Outline of Standard
(a) Purpose
(b) Scope
(c) Definitions
(d) Hazard Classification
(e) Written Hazard Communication Program
(f) Labels and Other Forms of Warning
(g) Safety Data Sheets
(h) Employee Information and Training
(i) Trade Secrets
(j) Effective Dates
(k) Other Standards Affected
(l) Appendices

6. Definitions
Terms no longer being defined due to changes
in terminology:
Hazard warning; identity; and material safety data
sheet (MSDS)
Terms revised to be consistent with the GHS:
Chemical; chemical name; hazardous chemical; health
hazard; label; mixture; physical hazard; and trade
secret

7. Definitions
The following terms are being added to the
definitions section:
Classification; hazard category; hazard class; hazard not
otherwise classified; hazard statement; label
elements; pictogram; precautionary statement;
product identifier; pyrophoric gas; safety data sheet
(SDS); signal word; simple asphyxiant; and substance
These terms are primarily related to the changes in
approach to evaluating hazards, and providing label
information

8. Definitions
“Chemical”
OSHA previously used ―chemical‖ to indicate both
substances and mixtures
OSHA has decided to continue using ―chemical‖ in the final
rule as meaning those situations where both substances
and mixtures are being addressed
―Hazardous chemical‖ means any chemical which is
classified as a physical hazard or a health hazard, a
simple asphyxiant, combustible dust, pyrophoric gas, or
hazard not otherwise classified

9. Definitions
“Hazards Not Otherwise Classified”
Classified identifies a hazard, but the evidence does not
meet the currently specified criteria covered by Haz Com
2012
Example: Static Accumulator, Magnetic, etc.
Information will be required on the safety data sheets in
Section 2
Hazard information on the label, is not mandatory, but can
be provided under supplementary information
Such hazards must also be addressed in worker training

10. Definitions
“Precautionary statement” means a
phrase that describes recommended
measures that should be taken to
minimize or prevent adverse effects
resulting from exposure to a hazardous
chemical, or improper storage or
handling.
For example: Wear face protection [for
Explosives, Division 1.1]

11. (d) Hazard Classification
 Each type of hazard covered is considered a ―hazard
class‖—such as acute toxicity, carcinogenicity
 However, most of these hazard classes are also sub-
divided into ―hazard categories‖ to reflect the degree of
severity of the effect
 This is the concept of ―classification‖—rather than just
determining that there is a hazardous effect
(carcinogenicity), there is also a finding of how severe
that effect might be (Category 1 or 2)

12. (d) Hazard Classification
Classification Provisions
Chemical manufacturers and importers must
classify each chemical they produce or import:
 Determine the appropriate hazard classes and associated
hazard categories
 Base this on an evaluation of the full range of available
data/evidence on the chemical (no testing is required)
 Use Appendix A for health hazard criteria and Appendix B
for physical hazard criteria
 The introduction to Appendix A provides the general
approach to classification, including bridging principles

13. Health Hazards Classifications
Hazard Class Hazard Category
Acute Toxicity 1 2 3 4
Skin Corrosion/Irritation 1A 1B 1C 2
Serious Eye Damage/ Eye 1 2A 2B
Irritation
Respiratory or Skin Sensitization 1
Germ Cell Mutagenicity 1A 1B 2
Carcinogenicity 1A 1B 2
Reproductive Toxicity 1A 1B 2 Lactation
STOT –
Single Exposure 1 2 3
STOT –
Repeated Exposure 1 2
Aspiration 1
Simple Asphyxiants Single Category

14. Physical Hazards
Hazard Class Hazard Category
Explosives Unstable Div 1.1 Div 1.2 Div 1.3 Div 1.4 Div 1.5 Div 1.6
Explosives
Flammable Gases 1 2
Flammable Aerosols 1 2
Oxidizing Gases 1
Gases under Pressure 1
Compressed Gases
Liquefied Gases
Refrigerated Liquefied Gases
Dissolved Gases
Flammable Liquids 1 2 3 4
Self-Reactive Chemicals Type A Type B Type C Type D Type E Type F Type G
Pyrophoric Liquids 1
Pyrophoric Solid 1
Pyrophoric Gases Single
category
Self-heating Chemicals 1 2
Chemicals, which in 1 2 3
contact with water, emit
flammable gases
Oxidizing Liquids 1 2 3
Oxidizing Solids 1 2 3
Organic Peroxides Type A Type B Type C Type D Type E Type F Type G
Corrosive to Metals 1
Combustible Dusts Single
Category

15. (e) Program Requirements
Written program
List of all hazardous chemicals
Addresses non-routine tasks
Discusses other contractors
responsibilities
Available upon request to any employee
or contractor

16. (e) Written Program
Describes how the
standard will be
implemented in that
facility
Contains a list of all
chemicals

17. (f) Labels
Required Elements
Product identifier
Signal words
Hazard statements
Pictograms
Precautionary statements
Name, address, and telephone number of the chemical
manufacturer, importer, or other responsible party
A new Appendix C, Allocation of Label Elements, has been
provided to indicate the label requirements by hazard
class and category
Labels are to be updated within 6 months of getting new
and significant information about the hazards, or ways
to protect those exposed

18. (f) Labels
 OSHA is maintaining the current approach to allowing
alternatives to labels on each stationary process
container
 The exception for portable containers under the control
of the person who filled them with the chemical remains
the same.
 Labels on incoming containers are not to be removed or
defaced unless immediately replaced by another label
 Workplace labels are to be prominently displayed and in
English, although other languages are permitted as well

19. Pictograms

20. (f) Labels Example

21. (f) Labels Sample HS85 Label
HS85
Warning
Batch number: 85L6543
Harmful if swallowed. Wash hands and face thoroughly after handling.
Do not eat, drink or smoke when using this product. Dispose of
contents/container in accordance with local, state and federal
regulations.
First aid: If swallowed: Call a doctor if you feel unwell. Rinse mouth.
GHS Example Company, 123 Global Circle, Anyville, NY 130XX
Emergency Telephone (888) 888-8888

23. (f) Labels
Employers are responsible for maintaining the labels on the
containers, including, but not limited to, tanks, totes,
drums, and for training their employees on the hazards
listed on the labels in the workplace.
Labels must continue to be:
legible
contain the pertinent information (such as the
hazards and directions for use)
not able to be defaced, (i.e., fade, get washed off,) or
removed in any way as stated in revised Hazard
Communication Standard, 29 CFR 1910.1200(f)(9)

24. (g) Safety Data Sheets (SDS)
 The GHS uses a specified order of information, as well
as title descriptions, on the 16-section safety data sheet.
 Health, physical and environmental hazard criteria for
substances and for classification of mixtures.
 Consistent with voluntary industry consensus standards,
such as ANSI.
 Should improve comprehensibility and issues regarding
accuracy of information.

25. (g) Safety Data Sheet Format
1. Identification of the 9. Physical and chemical
substance or mixture and properties
of the supplier 10. Stability and reactivity
2. Hazards identification 11. Toxicological information
3. Composition/information 12. Ecological information
on ingredients (non-mandatory)
4. First-aid measures 13. Disposal considerations
5. Fire-fighting measures (non-mandatory)
6. Accidental release 14. Transport information
measures (non-mandatory)
7. Handling and storage 15. Regulatory information
8. Exposure (non-mandatory)
controls/personal 16. Other information, including
protection date of preparation or last
revision

26. (g) Safety Data Sheets (SDS)
SDS in the workplace for each hazardous
chemical which is used
OSHA requires these forms for each hazardous
chemicals
Readily accessible during each work shift to
employees when they are in their work area(s)

27. (g) Safety Data Sheets (SDS)
Identifies chemicals by name
Tells potential harm and how chemicals
will enter the body (Inhalation, ingestion,
and/or skin absorption)
Explains signs and symptoms of
exposures
Explains emergency procedures

28. (h) Employee Training
Although this paragraph remains essentially the
same, updates include
Training to include label elements and new safety
data sheet format - by December 1, 2013
Training to reflect any new hazards identified in the
workplace - by June 1, 2016
Training – prescribed label elements and order of
information on data sheets facilitate
training/comprehensibility.

29. (h) Employee Training
Trained initially and
when new chemical Location of program,
introduced list of chemical, and
OSHA standard SDS
covered Detection of chemical
Operations in their Hazards of chemical
work area where Protection measures
chemical is used
Emergency
Pictograms
procedures
Labeling system used

30. Temporary Employees
 The temporary agency
employer would provide
generic hazard training and
information concerning
categories of chemicals
employees may potentially
encounter
 Host employers would then be
responsible for providing site-
specific hazard training
pursuant to sections
1910.1200(h)(1)

31. Compliance Issues
Can employees retrieve information
stored on a computer?
How do employees speaking other
language understand labels in English?
Who puts labels on portable containers?

32. More Issues
How is the outside contractor informed of
chemicals in the area?
What do you do if the label falls off an old
container?
How is chemical piping labeled?
What chemicals do I have that may
contain cancer causing chemicals?

33. Appendices
 Appendix A, Health Hazard Criteria (Mandatory) (NEW)
 Appendix B, Physical Hazard Criteria (Mandatory) (NEW)
 Appendix C, Allocation of Label Elements (Mandatory)
(NEW)
 Appendix D, Safety Data Sheets (Mandatory) (NEW)
 Appendix E, Definition of ―Trade Secret‖ (Mandatory)
 Appendix F, Guidance for Hazard Classifications re:
Carcinogenicity (Non-Mandatory) (NEW)

34. FLAMMABLE LIQUIDS
(Classified in Accordance with Appendix B.6)
Pictogram
Flame
Hazard Signal Hazard statement
category word
1 Danger Extremely flammable
liquid and vapor
2 Danger Highly flammable
liquid and vapor
3 Warning Flammable liquid and
vapor
Pictogram
No Pictogram
Hazard Signal Hazard statement
category word
4 Warning Combustible liquid

35. Revision of 29 CFR 1910.106
Flammable Liquids
Flammable liquids are divided into four categories as
follows:
(i) Category 1 . . . FPs below 73.4 o F (23 o C)
and having a BP at or below 95 o F (35 o C).
(ii) Category 2 . . . FPs below 73.4 o F (23 o C) and
BP above 95 o F (35 o C).
(iii) Category 3 . . . FPs at or above 73.4 o F (23
o C) and at or below 140 o F (60 o C).
(iv) Category 4 . . . FPs above 140 o F (60 o C)
and at or below 199.4 o F (93 o C).

36. Revision of 29 CFR 1910.106
Flammable Liquids
GHS Flammable and Combustible Liquids Standard
(29 CFR 1910.106)
Category Flashpoint ºC ( F) Boiling Class Flashpoint ºC ( F) Boiling Point
Point ºC ( F)
ºC ( F)
Flammable 1 < 23 (73.4) ≤ 35 (95) Flammable Class IA < 22.8 (73) < 37.8 (100)
Flammable 2 < 23 (73.4) > 35 (95) Flammable Class IB < 22.8 (73) ≥ 37.8 (100)
Flammable 3 ≥ 23 (73.4) and ≤ Flammable Class IC ≥ 22.8 (73) and < 37.8
60 (140) Combustible Class II (100)
≥ 37.8 (100) and < 60
(140)
Flammable 4 > 60 (140) and ≤93 Combustible Class IIIA ≥ 60 (140) and <93.3
(199.4) (200)
None Combustible Class IIIB ≥ 93.3 (200)
** Not covered by §1910.1200 or §1910.106 however interpretation letter indicates these are covered by §1910.107

37. Safety Standards
Flammable Liquids 1910.106
HCS 1994
Flame arresters or venting devices required in subdivision (f)
of this subdivision may be omitted for Class IB and IC liquids
where conditions are such that their use may, in case of
obstruction, result in tank damage.
HCS 2012
(g) Flame arresters or venting devices required in paragraph
(B)(2)(iv)(f) of this section may be omitted for Category 2
flammable liquids and Category 3 flammable liquids
with a flashpoint below 100 °F (37.8 °C) where
conditions are such that their use may, in case of
obstruction, result in tank damage.

38. Safety Standards
PSM 1910.119(a)(1)(ii)
HCS 1994
A process which involves a flammable liquid or gas (as
defined in 1910.1200(c) of this part) on site in one location,
in a quantity of 10,000 pounds (4535.9 kg).
HCS 2012
A process which involves a Category 1 flammable gas (as
defined in 1910.1200 (c)) or a flammable liquid with a
flashpoint below 100 °F (37.8 °C) on site in one
location, in a quantity of 10,000 pounds (4535.9 kg)

39. (j) Effective Dates
Requirement's) Who
Effective Completion Date
December 1, 2013 Train employees on the new label Employers
elements and safety data sheet (SDS)
format.
June 1, 2015* Compliance with all modified Chemical manufacturers, importers,
December 1, 2015 provisions of this final rule, except: distributors and employers
The Distributor shall not ship
containers labeled by the chemical
manufacturer or importer unless it is a
GHS label
June 1, 2016 Update alternative workplace labeling Employers
and hazard communication program
as necessary, and provide additional
employee training for newly identified
physical or health hazards.
Transition Period to the effective May comply with either 29 CFR Chemical manufacturers, importers,
completion dates noted above 1910.1200 (the final standard), or the distributors, and employers
current standard, or both

40. Quiz
1) The Pictogram in the upper right is for _____.
2) Training in the hazards of the chemical is initially and
when __________________.
3) _______ use containers would not require a label.
4) Name at least two things an employee would have to
be trained on for flammable paint:
________________ ___________________
5) SDS’s must be accessible to employees during their
_____________________________.
6) Name two chemicals that would be in the list of
hazardous chemicals? ___________
______________

41. Further
 This was prepared as a collaborative effort several
friends as a preliminary aid for anyone in the safety and
health field.
 These are just some the issues. A comprehensive job
hazard analysis should be conducted for any task where
someone can get hurt.
 This is not an official OSHA publication. Those will be on
the OSHA.gov website.
 If you see any errors my email is Newquist.john@dol.gov
 312-353-5977
 I want to thank Paul Saati, Joe H. Matt S. and Janet S.
for all their assistance in answering questions and
providing insight to the many hazards in this sector.
 Deana Holmes, Kathy Landkrohn, Jennifer Lawless, and
Maureen Ruskin conducted a webinar on this subject for
OSHA and their PowerPoint was a basis of this one.