Essential Steps for GHS Revision 7: Aligning with OSHA's HazCom Update

Preparing for OSHA’s Revised Hazard Communication Standard: A Guide for Manufacturers

With the recent revision of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) (Rev. 7), regulated entities around the globe must wrestle with what the revision will mean in their jurisdiction. Depending upon where manufacturers are located, different regulations will apply.  

The United States Occupational Safety and Health Administration (OSHA) recently amended its Hazard Communication Standard (HazCom) to align with this revision. Although the rule was effective as of July 2024, there are built in transitional periods for compliance – January 2026 for substances and July 2027 for mixtures. Given the massive task of updating (potentially) every Safety Data Sheet (SDS) and label for products, it is important for manufacturers to take the following 5 steps now, well in advance of the close of the transitional periods.  

Understanding the Hazard Communication Definition and Its Impact

Step 1: Understand OSHA's revised HazCom Final Rule and GHS Rev. 7  

Manufacturers need to fully understand the revision to OSHA's new HazCom final rule. Research into what changed, what the standard says (specific language), and what parts of the manufacturing process the standard impacts is vital. It is also important to understand the background/system on which OSHA based the revisions. By analyzing the GHS Rev. 7, manufacturers can understand the basis of why changes were made and the framework in which they were made.  

Note: Learn more about SDS updates by watching 3E's on-demand Webinar: U.S. SDS Updates Required by OSHA and TSCA.  

Step 2: Figure out what needs to be done for your specific company   

It is important to inventory all SDS and labels used for chemicals involved in the manufacturing process, as well as up and down the supply chain. This should be done at all facilities. Once the scope of work is determined, manufacturers need to come up with concrete steps to categorize which SDS and labels (etc.) must be revised, in what order they should be revised, and who in the company is responsible for the revisions.  

Note: Learn about 3E's tool for SDS management.   

Step 3: Get the team in place  

Resourcing will be an issue. Manufacturers subject to U.S. law have a relatively short timeframe to revise SDS and labels. Do you have the right team in place and the best technology to inventory your safety data sheet program? Do you know which external tools you need to get a bird's eye view of your compliance status as you update each SDS and label? Investing in the right resources at the start can save time in the future and lower the risk of noncompliance.  

Note: Outsource your SDS authoring to 3E.

Step 4: Develop a strategy/plan 

With an understanding of new regulatory requirements, a team in place, and effective technology, it is best to formalize a strategy or plan for transitioning all of your SDS and labels to be compliant with the revised Hazard Communication Standard and thus GHS Rev. 7. It might be helpful to work backwards from the transitional periods at play, prioritizing substances and then tackling mixtures. Given that this is a multi-year project, it is helpful to project manage accordingly.  

Note: Save time creating new SDS and updating existing ones. Use an integrated platform to manage risk. 

Step 5: Don't forget to look ahead 

The revised Hazard Communication Standard conforms to GHS Rev. 7 while also integrating a few elements from GHS Rev. 8. Thus, this is not necessarily the end of the road. It is going to be important to keep up to date on revisions in overarching systems like the GHS, and also regional and country-specific regulations that are revised/updated.  

Note: Stay informed of changes that impact your business directly. 

Leveraging Technology for Chemical Compliance

Changes that require full scale revisions of potentially hundreds or thousands of SDS and labels are daunting. With the right preparation and support, in both of human and technological resources, manufacturers will be ready to take on new challenges in regulatory monitoring.