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38 Pallet C e nt ral • July -Aug u st 2 0 24 SAFETY BY ADELE L. ABRAMS, ESQ., ASP, CMSP O n May 20, 2024, the federal Occupational Safety and Health Administration (OSHA) released its long-awaited revision to the Hazard Communication Standard (HCS, or HazCom), 29 CFR 1910.1200. If this sounds like déjà vu, just over a decade ago—in 2012—OSHA did its rst major revision to the rule since its inception in 1983 (for the chemical industry) and in 1989 (expanding it to cover all employers with hazardous chemical exposures or use). OSHA's HazCom standard is historically one of the top ve most frequently cited standards and was #2 in both FY 2022 and FY 2023, when over 3,200 citations were issued. HCS compliance is very paperwork-intensive, and each employee must have documented training on its provisions. It also interfaces to some degree with OSHA HAZWOPER, Process Safety Management, and Emergency Action Plan rules, as well as the EPA's Risk Management Program requirements, to the extent that those also apply to an employer or worksite. !e updated rule's provisions, outlined below, will take eect on July 19, 2024. !ere are staggered dates for compliance by chemical manufacturers, importers, and distributors evaluating substances ( January 19, 2026) and mixtures ( July 19, 2027). For employers, OSHA is providing six (6) months beyond those dates ( July 20, 2026, for substances; January 19, 2028, for mixtures) to update any alternative workplace labeling, update their written hazard communication program, and provide additional employee training for newly identied physical, health or other hazards as identied or reclassied under the nal rule. Until those eective dates, OSHA will accept compliance with either the current rule or the new standard. !e rule's focus is on improving the amount and quantity of information on labels (especially small product labels) and to enable workers and rst responders who use these sheets as a reference for rst aid, personal protective equipment, and emergency protocols to react more quickly in an emergency. It includes new denitions for the terms "bulk shipment," "combustible dust," "gas," "immediate outer package," OSHA REVISIONS TO HAZCOM STANDARD IMPOSE NEW REQUIREMENTS

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