A major overhaul is coming to the Occupational Safety and Health Administration’s (OSHA) Hazard Communication Standard (HCS) in 2025. These updates are meant to align the U.S. with the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) Revision 7, a global system for chemical safety. While the core purpose of HCS—ensuring workers are informed about chemical hazards—remains, the new rules introduce significant changes to labeling, Safety Data Sheets (SDSs), and hazard classification. Staying ahead of these changes is critical to avoiding costly penalties, reducing workplace risks, and ensuring a smooth transition.

Navigating New Requirements: Labels and SDS Revisions

The new HCS standard brings specific changes to how chemical information is presented, affecting both product labels and SDSs. Understanding these revisions is the first step to compliance.

Labeling Updates

Chemical labels will now have more specific requirements to ensure clear and consistent communication of hazards. Key updates include:

• Expanded Hazard Classification: The new standard expands the number of hazard classes and categories, meaning more chemicals will be classified as hazardous. This includes changes to classes for flammable gases and aerosols, and the addition of a new class for desensitized explosives.
• Small Container Labeling: A major change is the updated guidance for labeling small containers (100 mL or less). If a full label isn’t feasible, a pull-out label or tag can be used. For very small containers (3 mL or less), no label is required if it interferes with use, but the immediate outer packaging must contain the full label and a statement that the small container must be stored within it when not in use.
• Updated Label Elements: While the fundamental elements—product identifier, signal word (Danger or Warning), pictogram, hazard statement, and precautionary statements—remain, the new standard introduces more specific and clearer language to improve readability and comprehension. Precautionary statements, which describe protective measures, are now more standardized and may be combined to avoid redundancy.

Safety Data Sheet (SDS) Revisions

SDSs, previously known as Material Safety Data Sheets (MSDS), are the primary source of detailed chemical information. While the 16-section format remains the same, there are revisions to sections 2, 3, 9, and 11 to reflect the updated GHS standard.

• Enhanced Information: The new rule clarifies and adds detail to the information required in several sections. For example, Section 2 must now include hazards that may arise from a chemical’s change in physical form or from chemical reactions during known or anticipated uses.
• Trade Secret Provisions: The new standard provides clearer guidelines for manufacturers who claim a chemical ingredient’s concentration as a trade secret. It now allows for the use of prescribed concentration ranges to maintain confidentiality while still providing necessary hazard information.

Strengthening Hazard Communication and Training

Compliance with the new HCS isn’t just about updating documents; it’s about making sure your workforce fully understands and can apply the information. This means a proactive approach to safe material handling and a significant focus on employee training.

Safe Handling of Hazardous Materials

Effective hazard communication is the foundation of a safe workplace. By focusing on proper handling, you can drastically reduce the risk of incidents.

• Risk Assessments: With the updated hazard classifications, it’s crucial to re-evaluate your chemical inventory and conduct thorough risk assessments. This will help you identify new or re-classified hazards and adjust safety protocols accordingly.
• Personal Protective Equipment (PPE): Review your PPE requirements based on the new SDS information. Ensure employees have the correct gear for each task and are trained on its proper use, maintenance, and limitations.
• Emergency Preparedness: Update your emergency response plans to reflect the new hazard information. Employees should be trained on what to do in case of a chemical spill, fire, or exposure, including first-aid procedures and evacuation routes.

Implementing Updated Training Standards

OSHA requires employers to train their employees on the new HCS. This is not a one-time event. Training must be conducted at the time of initial assignment and whenever a new chemical hazard is introduced into the work area. The training should be in a language and manner that employees can understand and must cover:

• HCS Overview: The new standard’s requirements and how they impact the workplace.
• Label and SDS Interpretation: How to read and understand the updated labels and SDSs, and where to find them.
• Hazard Recognition: How to identify and understand the physical and health hazards of chemicals in their work area.
• Protective Measures: The specific controls and safety procedures in place to protect them, including engineering controls, work practices, and PPE.

Practical Strategies for a Smooth Transition

Transitioning to the new HCS can be complex, but with a clear strategy, it’s manageable. Here are some steps and a real-world case study analogy to help.

Improve Chemical Inventory Management

A robust chemical inventory system is essential for compliance. Start by conducting a full audit of all chemicals in your workplace.

• Centralized Database: Use a digital system or a comprehensive list to track all chemicals, their locations, and corresponding SDSs.
• Update SDSs and Labels: Contact your chemical suppliers to get the updated SDSs and new product labels. Implement a system to ensure new shipments arrive with compliant documentation and labeling.
• Assign Responsibility: Designate a point person or a team to oversee the transition, including managing the chemical inventory and training schedule.

Case Study Analogy: The “Compliance Checklist” Approach

Think of the HCS transition like a major software update. A large manufacturing company, let’s call it “SafeChem,” faced the challenge of updating thousands of chemical products and training a diverse workforce. Instead of a chaotic, company-wide change, they implemented a phased, checklist-based approach:

1. Phase 1: Audit & Acquisition: They first audited their entire chemical inventory. For each chemical, they created a checklist item to verify if an updated SDS was needed. If so, they contacted the supplier.
2. Phase 2: Documentation & Digitization: As updated SDSs arrived, they were uploaded to a centralized, searchable database accessible to all employees via tablets at each workstation. The old paper binders were phased out.
3. Phase 3: Training & Implementation: They developed short, department-specific training modules focused on the new labels and SDS format, using a “train-the-trainer” model where supervisors were first certified to teach their teams.
4. Phase 4: Verification & Ongoing Review: Regular, unannounced “spot checks” were conducted in different departments to ensure employees could correctly identify hazards and locate SDSs for chemicals in their area.

By treating the HCS update as a systematic project with clear steps and a dedicated team, SafeChem avoided penalties, improved their overall safety culture, and ensured their workforce was fully prepared for the changes. Implementing a similar strategic approach can help your organization navigate the HCS updates successfully.

The Impact on New York and Florida Construction

The HCS updates will have a particularly strong impact on the construction industry in states like New York and Florida, which have large, active construction sectors with extensive use of hazardous materials.

• Unique Challenges: Construction sites are dynamic environments, with chemicals constantly being brought in and out. This makes chemical inventory management and labeling a more significant challenge than in a fixed-location facility. The new, more detailed labeling requirements will demand a more rigorous system for tracking and verifying chemicals on site.
• Workforce Mobility: Construction workers are often mobile, moving between different job sites and contractors. This creates a need for consistent, universal training across the industry. Employers will be responsible for ensuring that all new and existing workers are properly trained on the new HCS standards, regardless of their prior experience.
• Climate and Hazards: The physical and health hazards of chemicals can be exacerbated by the extreme weather conditions common in New York (cold and ice) and Florida (heat and humidity). The updated SDSs, with more detailed information on physical and chemical properties, will be crucial for managing these risks. For example, a chemical that is stable in moderate temperatures might become more volatile in Florida’s heat, and the new SDSs are designed to provide this kind of critical information.

Compliance in these states will require not only updating labels and SDSs but also integrating these new standards into existing safety protocols for heat illness prevention, respiratory protection, and confined space entry.

John Caravella Esq., is a construction attorney and formerly practicing project architect at The Law Office of John Caravella, P.C., representing architects, engineers, contractors, subcontractors, and owners in all phases of contract preparation, litigation, and arbitration across New York and Florida. He also serves as an arbitrator to the American Arbitration Association Construction Industry Panel. Mr. Caravella can be reached by email: John@LIConstructionLaw.com or (631) 608-1346.

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Resources

• OSHA Hazard Communication Standard: The official OSHA website provides comprehensive information on the standard, including a small entity compliance guide and fact sheets.
• Globally Harmonized System (GHS): The United Nations’ website offers details on the GHS and its various revisions.
• OSHA Training Institute: Find courses and training materials on the HCS and other safety standards.
• Chemical Suppliers and Manufacturers: Your primary source for updated SDSs and labels. Proactively communicate with your suppliers to ensure a smooth transition.