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OSHA

Hazard Communication Requirements

As of July 2024, the Occupational Safety and Health Administration (OSHA) updated its Hazard Communication (HAZCOM) standard requirements. These requirements apply to concessioners, who must maintain regulatory compliance with these new standards.The OSHA HAZCOM standard has been in place for many years, and its general requirements apply to all employers, including concessioners. The specific requirements for concessioners include:

• Developing and implementing a written HAZCOM program that meets OSHA requirements.

• Maintaining an inventory of all chemicals used and stored in the workplace.

• Keeping Safety Data Sheets (SDSs) for all chemicals used and stored in the workplace.

• Labeling all chemical containers with the name and hazards of the chemicals.

• Training employees on the HAZCOM program.

Globally Harmonized System of Classification and Labeling of Chemicals
In 2024, OSHA revised the HAZCOM, also known as the "right-to-know" standard, to align with the seventh revision of the United Nations' Globally Harmonized System of Classification and Labelling of Chemicals (GHS). The rule was published on May 20, 2024, and became effective July 19, 2024. The updated Hazard Communication Standard (HCS) provides a consistent approach to classifying chemicals and communicating hazard information through labels and SDSs. This change aims to enhance the quality and consistency of hazard information, making the workplace safer for employees. Many of the HAZCOM requirements concessioners are familiar with remain the same. However, a few requirements have changed:

• Revised hazard classification criteria: Some health and physical hazard classification criteria have been updated (for example, aerosols, desensitized explosives, chemicals under pressure) to improve hazard communication.

• Small‑container labeling: There are now new provisions for labeling smaller containers, reflecting concerns about space and legibility on small packaging.

• SDS & label content updates: SDSs and labels must now contain updated precautionary statements and definitions, and reflect new hazard classes.

This revised standard not only ensures that employees have the "right-to-know" but also "right-to-understand." To comply with the new GHS requirements, concessioners should take the following steps:

1. Update their hazard communication program to reflect the new rule:

• Create an updated list of hazardous chemicals present
• Ensure proper container labeling and other forms of warning
• Develop procedures for SDS availability procedures
• Implement an employee information and training program
• Update alternative workplace labeling (if used)

2. Review all chemical containers in their facilities to ensure that labels meet the updated requirements or are prepared for new incoming labels from suppliers.
3. Review their SDS library to ensure that they have captured updated SDSs reflecting the 2024 HCS changes and replaced older versions where necessary.
4. Train employees (or update existing training) to cover:

• New terminology or definitions introduced by the 2024 rule
• New hazard‑classes/categories (e.g., aerosols, desensitized explosives, pressure hazards) and their impact on safe work practices.
• Changes in the format or content of labels and SDSs that employees will see
• Changes in documentation or reporting procedures for hazards under their program

5. Address alternative workplace labeling (if in use) to ensure their system (tags, signs, color coding, etc.) reflects any new hazard class or label‑content changes.
6. Document their compliance by maintaining training records, keeping the program current, updating the chemical inventory, ensuring all SDSs are up to date, and verifying that labels have been reviewed.

For more information, OSHA has provided resources to clarify the update for employers and employees, including:

• OSHA’s Correction Notice for the Final Rule to Amend the Hazard Communication Standard

• OSHA’s Final Rule to Amend the Hazard Communication Standard

• Questions & Answers for OSHA’s Update to the HCS Final Rule

OSHA also offers free training materials in English and Spanish on OSHA's website. If you have questions on implementing the GHS in your concession operations, contact us.