Section (d)(1) sets forth the requirements for chemical manufacturers. And importers to classify chemicals. And Sections (f) and (g) cover requirements for labeling and safety data sheets (SDSs). Although separate. These sections are relat, especially after OSHA align the. HCS with the Globally Harmoniz System of Classification and Labeling of Chemicals (GHS) in 2012. Previously, OSHA’s labeling and SDS requirements were more performance-orient. But the transition has been gradual. GHS introduc more prescriptive labeling and requir that all hazards be identifi. This was an issue because the hazards of a chemical, as packag by the manufacturer. Were different from the hazards generat by downstream users. Manufacturers question how they should present the information on the label and SDS.
To address this issue, in OSHA’s final rule, the language was updat to (d)(1):
- It recognizes that all hazards associat with the “intrinsic properties” of the chemical must be includ in the hazard classification.
- It is broken down into (d)(1) to (d)(1)(A) and (d)(1)(B) to distinguish between the chemical hazards of the chemical as it is shipp (including changes in physical form) and the hazards associat with the chemical’s reaction gambling data taiwan products (known or reasonably expect) in downstream applications. OSHA believes this clarifies the hazards that must be address and provides the necessary guidance on the information that must be includ on the label and SDS.
OSHA indicat that this change reaffirms the scope pursue clear goals language under (b)(2) and OSHA’s long-standing position that hazard classification must cover even hazards creat by chemical reactions that occur during known or reasonably anticipat uses.
Physical Hazards
Changes have been made to improve hazard communication, such as realigning categories and adding new ones such as desensitiz explosives. The main changes can be found in flammable gases, aerosols, and oxidizing solids.
Explosives
OSHA add two notes to the Explosive Hazard Class:
*Note 1: Identifies the new hazard class Desensitiz Explosives (B.17).
*Note 2: Indicates that a chemical may still have explosive properties even though it is exempt from classification as an explosive. In these cases, these properties must be indicat on the SDS.
One commenter not that the GHS made significant whatsapp filter revisions to the classification criteria for Explosive Hazard Classes in GHS Revision 9. While OSHA declin to adopt the classification criteria from the revision due to lack of notice, OSHA explain that there is already flexibility built into the labeling for explosives and in many cases following the GHS Revision 9 update, full compliance with the HCS will be achiev.