By Valerie Butera and Kate McMahon

On May 20, 2024, OSHA published a significant revision to the Hazard Communication Standard (HCS) in an effort to better align the HCS with the United Nations’ Globally Harmonized System of Classification, primarily Revision 7 (GHS).  This final rule also seeks to clarify ambiguities left unresolved by the last set of revisions to the HCS and to improve alignment with other federal agencies and international trading partners.

In making these changes, OSHA has created a host of new regulatory hurdles for chemical manufacturers, importers, distributors, and downstream users.  The final rule becomes effective July 20, 2024, but offers a grace period during which the regulated community may comply with the final rule or the prior version of the HCS.

CMC sat down with Maureen Ruskin, the now-former OSHA official who led the effort to align the HCS with the GHS, to discuss the changes in this final rule.  Our conversation informed this Client Alert, which begins with an overview of the biggest impacts the final rule will have on the regulated community and the timeline for coming into compliance with the new and changed requirements, provides a detailed discussion of what the final rule says and means, explores significant changes between the language of the proposed rule and what was actually adopted in the final rule, and explores tips and strategies for compliance.

Implications for the Regulated Community

The final rule impacts nearly every aspect of hazard communication – from Continue reading →