OSHA Gives Update on HCS 2024

Written By: Atanu Das on Tuesday, October 7, 2025

Major Updates: GHS Alignment and More

The revised HCS primarily aligns with the Globally Harmonized System (GHS) Revision 7, with select elements drawn from Revision 8. This update helps the U.S. standard keep pace with international partners, including the EU, Canada, Australia, and New Zealand, and supports consistency for companies operating across borders.

Some notable changes include:

• Incorporation of new GHS pictograms for hazard communication.
• Clarifications on physical hazards such as combinations of hazards, new guidance on the formation of flammable vapors or gases, and updates regarding explosives.
• Expanded criteria and guidance for health hazards, including non-animal test methods, germ cell mutagenicity, and potential endocrine disruptors.
• Emerging environmental concerns, addressing persistence and mobility hazards.
• Improvements in regulatory clarity, such as changes from “should” to “shall” in select areas and greater detail in GHS annexes.

Key Compliance Deadlines

The first major compliance date is set for January 2026. This gives manufacturers, importers, and employers ample time to adjust their programs, labels, and Safety Data Sheets (SDSs) to the new requirements.

Enforcement Data and Most Frequent Violations

OSHA continues to take HazCom compliance seriously. In Fiscal Year 2024, there were 1,737 federal inspections involving HCS violations, resulting in 3,107 citations and over $4.8 million in penalties. The most commonly cited issues were:

• Incomplete or outdated HCS programs.
• Insufficient employee training.
• Poor maintenance and accessibility of SDSs.
• Failure to develop or maintain SDSs.
• Improper workplace labeling.

SDS and Labeling Clarifications

A common question is what hazard information must appear on the SDS versus the label. Hazards classified under section d1(ii) (such as Hazards Not Otherwise Classified, or HNOC) must be listed in Section 2 of the SDS but do not require labeling on the container. This distinction is clarified in 29 CFR 1910.1200(f)(1).

Importers must ensure new labels consistent with HCS 2024 are affixed once they assume control of hazardous chemical containers, following long-standing OSHA guidance. For products seeking the articles exemption, both shipped-form hazards and hazards that may emerge during normal use or in emergencies must be considered.

Letters of Interpretation and Recent Guidance

OSHA continues to issue interpretations to help industry apply the updated standard. Recent guidance addresses topics such as emergency eyewash requirements for exposures to formaldehyde concentrations of 0.1% or greater.

Final Thoughts

OSHA’s 2024 changes to the Hazard Communication Standard reinforce the agency’s commitment to protecting workers while supporting international harmonization. EHS professionals should review internal programs, retrain staff as needed, and work proactively to meet the 2026 compliance deadline to minimize the risk of costly violations.