OSHA HazCom Updates: What GHS Revisions 7 & 8 Mean for Your Chemicals

OSHA’s updated Hazard Communication Standard (HazCom) is changing how certain chemical hazards are classified and communicated. But what does that mean for companies with hazardous chemicals in the workplace?

The short answer: not every chemical needs to be changed. The first step is identifying which chemicals are affected and ensuring their hazard classifications, labels, Safety Data Sheets (SDSs), and workplace communication are up to date.

OSHA published its final HazCom rule on May 20, 2024. The update became effective July 19, 2024, and is primarily aligned with GHS Revision 7, while incorporating certain elements from later GHS developments.

What Changed in OSHA’s HazCom Standard?

Key changes include:

• Updated hazard classification criteria for certain physical and health hazards
• A new hazard class for desensitized explosives
• Changes affecting certain flammable gases and aerosols
• Updated label requirements, including provisions for certain small containers
• Changes to information required on Safety Data Sheets
• Updates involving trade-secret information
• Changes intended to improve information available to workers and emergency responders

Manufacturers and importers may need to review how their products are classified and communicated. Employers using chemicals should ensure supplier information is current and workplace HazCom practices reflect any newly identified hazards.

Do Your Chemicals Need to Be Updated?

Don't assume every chemical in your inventory needs a new label or SDS.

Instead, review your inventory and identify products that may be affected by the revised classification criteria.

For each chemical, ask:

1. Has the manufacturer or supplier issued an updated SDS?
2. Has the chemical’s hazard classification changed?
3. Have new hazards been identified?
4. Does the product label need to change?
5. Do workplace procedures or employee training need to be updated?

If you manufacture or import chemicals, you may need to evaluate them under the revised classification requirements. If you use chemicals, work with suppliers to obtain current SDS and label information.

What Should You Do If a Chemical’s Classification Changes?

If a chemical has been reclassified or has new hazard information, treat the update as more than an SDS replacement.

1. Review the Hazard Classification

Confirm what changed and why. A classification change can affect the hazard information communicated throughout the chemical’s lifecycle.

2. Check the Label

A classification change may require updated:

• Signal words
• Hazard statements
• Pictograms
• Precautionary statements
• Product identifiers
• Supplier information

Employers should also verify that workplace containers clearly identify the chemical and its hazards.

3. Update the SDS

Make sure the current SDS is available to employees who may be exposed.

The revised HazCom requirements include changes to SDS information. OSHA’s SDS requirements are detailed in Appendix D of 29 CFR 1910.1200.

If a supplier provides a revised SDS, update your records and manage the outdated version appropriately.

4. Review Your HazCom Program

A chemical update shouldn't end with the SDS and label. Determine whether your written Hazard Communication Program, workplace labeling procedures, chemical inventory, or other practices need to be updated.

5. Train Employees When Necessary

Employees need to understand newly identified hazards and changes affecting how they work with the chemical.

Training should focus on what has changed, such as a new hazard classification, label element, precaution, or protective measure.

Don’t Forget the Compliance Dates

OSHA’s HazCom update uses a phased compliance schedule. OSHA extended the original dates by four months in January 2026.

For employers, the current deadlines are November 20, 2026, for substances and May 19, 2028, for mixtures. Manufacturers, importers, and distributors have earlier deadlines for evaluating and updating substances and mixtures.

Now is a good time to review your chemical inventory rather than waiting until the applicable deadline.

A Simple Approach to HazCom Updates

For most organizations:

Identify → Review → Update → Communicate → Train

• Identify chemicals that may be affected.
• Review their classifications, labels, and SDSs.
• Update documents and workplace practices that need to change.
• Communicate new hazard information to affected employees.
• Train employees on newly identified hazards and changes to safe handling practices.

The goal isn't to update everything simply because OSHA’s HazCom Standard changed. The goal is to identify the chemicals that are actually affected and make sure the right hazard information follows those chemicals from the label and SDS to the workplace.

Need Help Managing Your HazCom Updates?

Keeping track of chemical classifications, SDS revisions, labels, and employee training can be complicated, especially when your inventory includes products from multiple suppliers.

OSHEPRO can help organizations simplify the process of identifying and managing HazCom updates.

If you're reviewing your chemical inventory for OSHA’s updated requirements, contact OSHEPRO to learn how we can help you stay organized, current, and ready for the next step in your HazCom compliance program.