OSHA has proposed to modify the Hazard Communication Standard (29 CFR § 1910.1200) and the substance specific standards (29 CFR § 1910.1001–1052) to incorporate the Globally Harmonized System for the Classification and Labelling of Chemicals (GHS). A Notice of Proposed Rulemaking was issued on September 30, 2009.
This paper will provide a brief history of hazard communication in the United States, what the proposed rulemaking covers, and what potential changes there will be to the hazard communication standard in the future. It is important to note that, until the proposed rulemaking undergoes the entire rulemaking process and the adoption period has begun, the current Hazard Communication System (HCS) will remain in effect. The GHS uses the term Safety Data Sheets (SDS), as compared to the term Material Safety Data Sheets (MSDS); that terminology will be used for the remainder of this paper.