Side-by-Side Comparison of OSHA's Existing Hazard Communication Standard (HCS 1994)
vs. the Revised Hazard Communication Standard (HCS 2012)
This document provides a comparison of the changes from the existing Hazard Communication Standard (the current Hazard Communication Standard, 1910.1200, as published in the Code of Federal Regulations (CFR) on March 11, 1994; herein referred to as HCS 1994) and the final rule revising the Hazard Communication Standard to be consistent with the United Nations Globally Harmonized System of Classification and Labelling of Chemicals (herein referred to as the HCS 2012).
The HCS 1994 is a performance-oriented standard that provides guidance for defining hazards and for performing hazard determinations. However, the current standard does not specify an approach or format to follow. The Globally Harmonized System of Classification and Labelling of Chemicals (GHS) has certain aspects that are performance-oriented, but the key provisions are a uniformity-oriented approach for the classification and presentation, through labeling and safety data sheets, of hazard information.
The HCS 2012 is written as a modification to the existing standard, and those parts of the standard that do not relate to the GHS, or are already consistent with it remain unchanged. Additionally, some minor changes to terminology have been made in order to align this rule with language used in the GHS. For example, the term "hazard determination" has been changed to "hazard classification" and "material safety data sheet" has been changed to "safety data sheet."
The following side-by-side comparison shows the changes made to the HCS 1994 as stricken text in the left-hand column. Additions or changes made to the existing HCS (1994) to create the revised HCS (aligning the HCS with the GHS, and effective 2012) are shown as underlined text in the right-hand column.
Purpose.
The Hazard Communication Standard (HCS) 1994 includes a paragraph that describes the purpose of the HCS, and addresses preemption of state and local laws. The Hazard Communication Standard (HCS 2012) includes essentially the same paragraph as the HCS 1994. The primary modification to this paragraph is to state affirmatively that part of the purpose is to harmonize with international requirements. OSHA also clarified the standard's preemptive affect on State laws. Other than terminology, no additional substantive changes have been made in this paragraph of the HCS. |
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HCS 1994 | HCS 2012 |
(a) Purpose. (a)(1) The purpose of this section is to ensure that the hazards of all chemicals produced or imported are (a)(2) This occupational safety and health standard is intended to address comprehensively the issue of |
(a) Purpose. (a)(1) The purpose of this section is to ensure that the hazards of all chemicals produced or imported are classified, and that information concerning the classified hazards is transmitted to employers and employees. The requirements of this section are intended to be consistent with the provisions of the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS), Revision 3. The transmittal of information is to be accomplished by means of comprehensive hazard communication programs, which are to include container labeling and other forms of warning, safety data sheets and employee training. (a)(2) This occupational safety and health standard is intended to address comprehensively the issue of classifying the potential hazards of chemicals, and communicating information concerning hazards and appropriate protective measures to employees, and to preempt any legislative or regulatory enactments of a state, or political subdivision of a state, pertaining to this subject. Classifying the potential hazards of chemicals and communicating information concerning hazards and appropriate protective measures to employees, may include, for example, but is not limited to, provisions for: developing and maintaining a written hazard communication program for the workplace, including lists of hazardous chemicals present; labeling of containers of chemicals in the workplace, as well as of containers of chemicals being shipped to other workplaces; preparation and distribution of safety data sheets to employees and downstream employers; and development and implementation of employee training programs regarding hazards of chemicals and protective measures. Under section 18 of the Act, no state or political subdivision of a state may adopt or enforce any requirement relating to the issue addressed by this Federal standard, except pursuant to a Federally-approved state plan. |
Scope and Application.
Definitions.
Several key changes have been made to update the definitions section. This final rule provides more detailed physical and health hazard criteria. However, this information has now been moved from this section into Appendices A and B. Additionally, in order to be consistent with the GHS, OSHA has added, deleted, and modified a number of the definitions. The following changes were made to definitions in the HCS 2012: Added the following definitions: Classification, Hazard category, Hazard class, Hazard not otherwise classified, Hazard statement, Label elements, Pictogram, Precautionary statement, Product identifier, Pyrophoric Gas, Safety data sheet, Signal word, Simple asphyxiant, and Substance. Deleted the following definitions: Combustible liquid, Compressed gas, Explosive, Flammable, Flashpoint, Hazard warning, Identity, Material safety data sheet, Organic peroxide, Oxidizer, Pyrophoric, Unstable (reactive), and Water-reactive. Revised the following definitions: Chemical, Chemical name, Hazardous chemical, Health hazard, Label, Mixture, Physical hazard, and Trade secret. The definition of Hazardous Chemical was located incorrectly in the HCS 1994 and here in this document it has been properly relocated to where it should have been placed in the correct alphabetical order. While it remains an important definition in both the HCS 1994 and the HCS 2012, the proper relocation in alphabetical order is the reason for this definition being struck in the Refer to the Summary and Explanation of the Final Rule to gain a better understanding of the changes. |
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HCS 1994 | HCS 2012 |
(c) Definitions. "Article" means a manufactured item other than a fluid or particle: (i) which is formed to a specific shape or design during manufacture; (ii) which has end use function(s) dependent in whole or in part upon its shape or design during end use; and (iii) which under normal conditions of use does not release more than very small quantities, e.g., minute or trace amounts of a hazardous chemical (as determined under paragraph (d) of this section), and does not pose a physical hazard or health risk to employees. "Assistant Secretary" means the Assistant Secretary of Labor for Occupational Safety and Health, U.S. Department of Labor, or designee. "Chemical" means any "Chemical manufacturer" means an employer with a workplace where chemical(s) are produced for use or distribution. "Chemical name" means the scientific designation of a chemical in accordance with the nomenclature system developed by the International Union of Pure and Applied Chemistry (IUPAC) or the Chemical Abstracts Service (CAS) rules of nomenclature, or a name
"Commercial account" means an arrangement whereby a retail distributor sells hazardous chemicals to an employer, generally in large quantities over time and/or at costs that are below the regular retail price. "Common name" means any designation or identification such as code name, code number, trade name, brand name or generic name used to identify a chemical other than by its chemical name.
"Container" means any bag, barrel, bottle, box, can, cylinder, drum, reaction vessel, storage tank, or the like that contains a hazardous chemical. For purposes of this section, pipes or piping systems, and engines, fuel tanks, or other operating systems in a vehicle, are not considered to be containers. "Designated representative" means any individual or organization to whom an employee gives written authorization to exercise such employee's rights under this section. A recognized or certified collective bargaining agent shall be treated automatically as a designated representative without regard to written employee authorization. "Director" means the Director, National Institute for Occupational Safety and Health, U.S. Department of Health and Human Services, or designee. "Distributor" means a business, other than a chemical manufacturer or importer, which supplies hazardous chemicals to other distributors or to employers. "Employee" means a worker who may be exposed to hazardous chemicals under normal operating conditions or in foreseeable emergencies. Workers such as office workers or bank tellers who encounter hazardous chemicals only in non-routine, isolated instances are not covered. "Employer" means a person engaged in a business where chemicals are either used, distributed, or are produced for use or distribution, including a contractor or subcontractor.
"Exposure or exposed" means that an employee is subjected in the course of employment to a chemical that is a physical or health hazard, and includes potential (e.g. accidental or possible) exposure. "Subjected" in terms of health hazards includes any route of entry (e.g. inhalation, ingestion, skin contact or absorption.)
"Foreseeable emergency" means any potential occurrence such as, but not limited to, equipment failure, rupture of containers, or failure of control equipment which could result in an uncontrolled release of a hazardous chemical into the workplace.
"Health hazard" means a chemical
"Immediate use" means that the hazardous chemical will be under the control of and used only by the person who transfers it from a labeled container and only within the work shift in which it is transferred. "Importer" means the first business with employees within the Customs Territory of the United States which receives hazardous chemicals produced in other countries for the purpose of supplying them to distributors or employers within the United States. "Label" means " "Mixture" means
"Physical hazard" means a chemical "Produce" means to manufacture, process, formulate, blend, extract, generate, emit, or repackage. "Pyrophoric "Responsible party" means someone who can provide additional information on the hazardous chemical and appropriate emergency procedures, if necessary. "Specific chemical identity" means the chemical name, Chemical Abstracts Service (CAS) Registry Number, or any other information that reveals the precise chemical designation of the substance. "Trade secret" means any confidential formula, pattern, process, device, information or compilation of information that is used in an employer's business, and that gives the employer an opportunity to obtain an advantage over competitors who do not know or use it.
"Use" means to package, handle, react, emit, extract, generate as a byproduct, or transfer.
"Work area" means a room or defined space in a workplace where hazardous chemicals are produced or used, and where employees are present. "Workplace" means an establishment, job site, or project, at one geographical location containing one or more work areas. |
(c) Definitions. "Article" means a manufactured item other than a fluid or particle: (i) which is formed to a specific shape or design during manufacture; (ii) which has end use function(s) dependent in whole or in part upon its shape or design during end use; and (iii) which under normal conditions of use does not release more than very small quantities, e.g., minute or trace amounts of a hazardous chemical (as determined under paragraph (d) of this section), and does not pose a physical hazard or health risk to employees. "Assistant Secretary" means the Assistant Secretary of Labor for Occupational Safety and Health, U.S. Department of Labor, or designee. "Chemical" means any substance, or mixture of substances. "Chemical manufacturer" means an employer with a workplace where chemical(s) are produced for use or distribution. "Chemical name" means the scientific designation of a chemical in accordance with the nomenclature system developed by the International Union of Pure and Applied Chemistry (IUPAC) or the Chemical Abstracts Service (CAS) rules of nomenclature, or a name that will clearly identify the chemical for the purpose of conducting a hazard classification. "Classification" means to identify the relevant data regarding the hazards of a chemical; review those data to ascertain the hazards associated with the chemical; and decide whether the chemical will be classified as hazardous according to the definition of hazardous chemical in this section. In addition, classification for health and physical hazards includes the determination of the degree of hazard, where appropriate, by comparing the data with the criteria for health and physical hazards. "Commercial account" means an arrangement whereby a retail distributor sells hazardous chemicals to an employer, generally in large quantities over time and/or at costs that are below the regular retail price. "Common name" means any designation or identification such as code name, code number, trade name, brand name or generic name used to identify a chemical other than by its chemical name. "Container" means any bag, barrel, bottle, box, can, cylinder, drum, reaction vessel, storage tank, or the like that contains a hazardous chemical. For purposes of this section, pipes or piping systems, and engines, fuel tanks, or other operating systems in a vehicle, are not considered to be containers. "Designated representative" means any individual or organization to whom an employee gives written authorization to exercise such employee's rights under this section. A recognized or certified collective bargaining agent shall be treated automatically as a designated representative without regard to written employee authorization. "Director" means the Director, National Institute for Occupational Safety and Health, U.S. Department of Health and Human Services, or designee. "Distributor" means a business, other than a chemical manufacturer or importer, which supplies hazardous chemicals to other distributors or to employers. "Employee" means a worker who may be exposed to hazardous chemicals under normal operating conditions or in foreseeable emergencies. Workers such as office workers or bank tellers who encounter hazardous chemicals only in non-routine, isolated instances are not covered. "Employer" means a person engaged in a business where chemicals are either used, distributed, or are produced for use or distribution, including a contractor or subcontractor. "Exposure or exposed" means that an employee is subjected in the course of employment to a chemical that is a physical or health hazard, and includes potential (e.g. accidental or possible) exposure. "Subjected" in terms of health hazards includes any route of entry (e.g. inhalation, ingestion, skin contact or absorption.) "Foreseeable emergency" means any potential occurrence such as, but not limited to, equipment failure, rupture of containers, or failure of control equipment which could result in an uncontrolled release of a hazardous chemical into the workplace. "Hazard category" means the division of criteria within each hazard class, e.g., oral acute toxicity and flammable liquids include four hazard categories. These categories compare hazard severity within a hazard class and should not be taken as a comparison of hazard categories more generally. "Hazard class" means the nature of the physical or health hazards, e.g., flammable solid, carcinogen, oral acute toxicity. "Hazard not otherwise classified (HNOC)" means an adverse physical or health effect identified through evaluation of scientific evidence during the classification process that does not meet the specified criteria for the physical and health hazard classes addressed in this section. This does not extend coverage to adverse physical and health effects for which there is a hazard class addressed in this section, but the effect either falls below the cut-off value/concentration limit of the hazard class or is under a GHS hazard category that has not been adopted by OSHA (e.g., acute toxicity Category 5). "Hazard statement" means a statement assigned to a hazard class and category that describes the nature of the hazard(s) of a chemical, including, where appropriate, the degree of hazard. "Hazardous chemical" means any chemical which is classified as a physical hazard or a health hazard, a simple asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise classified. "Health hazard" means a chemical which is classified as posing one of the following hazardous effects: acute toxicity (any route of exposure); skin corrosion or irritation; serious eye damage or eye irritation; respiratory or skin sensitization; germ cell mutagenicity; carcinogenicity; reproductive toxicity; specific target organ toxicity (single or repeated exposure); or aspiration hazard. The criteria for determining whether a chemical is classified as a health hazard are detailed in Appendix A to §1910.1200 -- Health Hazard Criteria. "Immediate use" means that the hazardous chemical will be under the control of and used only by the person who transfers it from a labeled container and only within the work shift in which it is transferred. "Importer" means the first business with employees within the Customs Territory of the United States which receives hazardous chemicals produced in other countries for the purpose of supplying them to distributors or employers within the United States. "Label" means an appropriate group of written, printed or graphic information elements concerning a hazardous chemical that is affixed to, printed on, or attached to the immediate container of a hazardous chemical, or to the outside packaging. "Label elements" means the specified pictogram, hazard statement, signal word and precautionary statement for each hazard class and category. "Mixture" means a combination or a solution composed of two or more substances in which they do not react. "Physical hazard" means a chemical that is classified as posing one of the following hazardous effects: explosive; flammable (gases, aerosols, liquids, or solids); oxidizer (liquid, solid or gas); self-reactive; pyrophoric (liquid or solid); self-heating; organic peroxide; corrosive to metal; gas under pressure; or in contact with water emits flammable gas. See Appendix B to §1910.1200 -- Physical Hazard Criteria. "Pictogram" means a composition that may include a symbol plus other graphic elements, such as a border, background pattern, or color, that is intended to convey specific information about the hazards of a chemical. Eight pictograms are designated under this standard for application to a hazard category. "Precautionary statement" means a phrase that describes recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical, or improper storage or handling. "Product identifier" means the name or number used for a hazardous chemical on a label or in the SDS. It provides a unique means by which the user can identify the chemical. The product identifier used shall permit cross-references to be made among the list of hazardous chemicals required in the written hazard communication program, the label and the SDS. "Produce" means to manufacture, process, formulate, blend, extract, generate, emit, or repackage. "Pyrophoric gas" means a chemical in a gaseous state that will ignite spontaneously in air at a temperature of 130 degrees F (54.4 degrees C) or below. "Responsible party" means someone who can provide additional information on the hazardous chemical and appropriate emergency procedures, if necessary. "Safety data sheet (SDS)" means written or printed material concerning a hazardous chemical that is prepared in accordance with paragraph (g) of this section. "Signal word" means a word used to indicate the relative level of severity of hazard and alert the reader to a potential hazard on the label. The signal words used in this section are "danger" and "warning." "Danger" is used for the more severe hazards, while "warning" is used for the less severe. "Simple asphyxiant" means a substance or mixture that displaces oxygen in the ambient atmosphere, and can thus cause oxygen deprivation in those who are exposed, leading to unconsciousness and death. "Specific chemical identity" means the chemical name, Chemical Abstracts Service (CAS) Registry Number, or any other information that reveals the precise chemical designation of the substance. "Substance" means chemical elements and their compounds in the natural state or obtained by any production process, including any additive necessary to preserve the stability of the product and any impurities deriving from the process used, but excluding any solvent which may be separated without affecting the stability of the substance or changing its composition. "Trade secret" means any confidential formula, pattern, process, device, information or compilation of information that is used in an employer's business, and that gives the employer an opportunity to obtain an advantage over competitors who do not know or use it. Appendix E to §1910.1200–Definition of Trade Secret, sets out the criteria to be used in evaluating trade secrets. "Use" means to package, handle, react, emit, extract, generate as a byproduct, or transfer. "Work area" means a room or defined space in a workplace where hazardous chemicals are produced or used, and where employees are present. "Workplace" means an establishment, job site, or project, at one geographical location containing one or more work areas. |
Hazard classification.
Hazard Communication Program.
This section of the HCS 1994 was retained. As the GHS does not include any requirements regarding Hazards Communication Programs, OSHA is maintaining the provisions of the HCS 1994. No substantive changes (only terminology) have been made in this paragraph of the HCS. |
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HCS 1994 | HCS 2012 |
(e) Written hazard communication program. (e)(1) Employers shall develop, implement, and maintain at each workplace, a written hazard communication program which at least describes how the criteria specified in paragraphs (f), (g), and (h) of this section for labels and other forms of warning, (e)(1)(i) A list of the hazardous chemicals known to be present using (e)(1)(ii) The methods the employer will use to inform employees of the hazards of non-routine tasks (for example, the cleaning of reactor vessels), and the hazards associated with chemicals contained in unlabeled pipes in their work areas. (e)(2) "Multi-employer workplaces." Employers who produce, use, or store hazardous chemicals at a workplace in such a way that the employees of other employer(s) may be exposed (for example, employees of a construction contractor working on-site) shall additionally ensure that the hazard communication programs developed and implemented under this paragraph (e) include the following: (e)(2)(i) The methods the employer will use to provide the other employer(s) on-site access to (e)(2)(ii) The methods the employer will use to inform the other employer(s) of any precautionary measures that need to be taken to protect employees during the workplace's normal operating conditions and in foreseeable emergencies; and, (e)(2)(iii) The methods the employer will use to inform the other employer(s) of the labeling system used in the workplace. (e)(3) The employer may rely on an existing hazard communication program to comply with these requirements, provided that it meets the criteria established in this paragraph (e). (e)(4) The employer shall make the written hazard communication program available, upon request, to employees, their designated representatives, the Assistant Secretary and the Director, in accordance with the requirements of 29 CFR 1910.1020 (e). (e)(5) Where employees must travel between workplaces during a workshift, i.e., their work is carried out at more than one geographical location, the written hazard communication program may be kept at the primary workplace facility. |
(e) Written hazard communication program. (e)(1) Employers shall develop, implement, and maintain at each workplace, a written hazard communication program which at least describes how the criteria specified in paragraphs (f), (g), and (h) of this section for labels and other forms of warning, safety data sheets, and employee information and training will be met, and which also includes the following: (e)(1)(i) A list of the hazardous chemicals known to be present using a product identifier that is referenced on the appropriate safety data sheet (the list may be compiled for the workplace as a whole or for individual work areas); and, (e)(1)(ii) The methods the employer will use to inform employees of the hazards of non-routine tasks (for example, the cleaning of reactor vessels), and the hazards associated with chemicals contained in unlabeled pipes in their work areas. (e)(2) "Multi-employer workplaces." Employers who produce, use, or store hazardous chemicals at a workplace in such a way that the employees of other employer(s) may be exposed (for example, employees of a construction contractor working on-site) shall additionally ensure that the hazard communication programs developed and implemented under this paragraph (e) include the following: (e)(2)(i) The methods the employer will use to provide the other employer(s) on-site access to safety data sheets for each hazardous chemical the other employer(s)' employees may be exposed to while working; (e)(2)(ii) The methods the employer will use to inform the other employer(s) of any precautionary measures that need to be taken to protect employees during the workplace's normal operating conditions and in foreseeable emergencies; and, (e)(2)(iii) The methods the employer will use to inform the other employer(s) of the labeling system used in the workplace. (e)(3) The employer may rely on an existing hazard communication program to comply with these requirements, provided that it meets the criteria established in this paragraph (e). (e)(4) The employer shall make the written hazard communication program available, upon request, to employees, their designated representatives, the Assistant Secretary and the Director, in accordance with the requirements of 29 CFR 1910.1020 (e). (e)(5) Where employees must travel between workplaces during a workshift, i.e., their work is carried out at more than one geographical location, the written hazard communication program may be kept at the primary workplace facility. |
Labels.
Health Hazard
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Flame
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Exclamation Mark
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Gas Cylinder
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Corrosion
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Exploding Bomb
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Flame Over Circle
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Environment(Non-Mandatory)
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Skull and Crossbones
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Safety Data Sheets.
Training and Information.
Trade secrets.
OSHA's final rule requires employers to train employees on the new label elements and safety data sheet format by December 1, 2013. All other provisions are to be in effect by June 1, 2015, with two exceptions. First, distributors will be given an extra six months to ensure all manufacturer labels are updated. Second, all employers will have an additional year to ensure that updated workplace signs, hazard communication program, and auxiliary training necessary for newly identified physical or health hazards, as provided in (h)(1), are in place. |
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HCS 1994 | HCS 2012 |
(j) Effective dates. Chemical manufacturers, importers, distributors, and employers shall be in compliance with all
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(j) Effective dates. (j)(1) Employers shall train employees regarding the new label elements and safety data sheets format by December 1, 2013. (j)(2) Chemical manufacturers, importers, distributors, and employers shall be in compliance with all modified provisions of this section no later than June 1, 2015, except: (j)(2)(i) After December 1, 2015, the distributor shall not ship containers labeled by the chemical manufacturer or importer unless the label has been modified to comply with paragraph (f)(1) of this section. (j)(2) (ii) All employers shall, as necessary, update any alternative workplace labeling used under paragraph (f)(6) of this section, update the hazard communication program required by paragraph (h)(1), and provide any additional employee training in accordance with paragraph (h)(3) for newly identified physical or health hazards no later than June 1, 2016. (j)(3) Chemical manufacturers, importers, distributors, and employers may comply with either §1910.1200, revised as of October 1, 2011, or the current version of this standard or both during the transition period. |
Appendix
Section-By-Section Comparison of the Changes to Safety Data Sheets to the Requirements of the 1994 Hazard Communication Standard
Section 1. Identification: The requirements in this section are not new except for format and the requirement to list recommended uses and restrictions on use.
HCS 1994 | HCS 2012 |
· Product identity same as on label and common names (g)(2)(i)(A) - (C) · Name address and telephone number of the manufacturer, distributor, employer or other responsible party (g)(2)(xii) |
1. Identification (a) Product identifier used on the label; (b) Other means of identification; (c) Recommended use of the chemical and restrictions on use; (d) Name, address, and telephone number of the manufacturer, importer, or other responsible party; (e) Emergency phone number. |
Section 2. Hazard(s) identification: In this section, the employer must identify the hazards according to the new classification criteria in Appendices A and B. Pictograms, standardized hazard statements, signal words, and precautionary statements are now required.
HCS 1994 | HCS 2012 |
· Physical hazards (g)(2)(iii) · Health hazards (g)(2)(iv) |
2. Hazard(s) identification (a) Classification of the chemical in accordance with paragraph (d) of §1910.1200; (b) Signal word, hazard statement(s), symbol(s) and precautionary statement(s) in accordance with paragraph (f) of §1910.1200. (Hazard symbols may be provided as graphical reproductions in black and white or the name of the symbol, e.g., flame, skull and crossbones); (c) Describe any hazards not otherwise classified that have been identified during the classification process; (d) Where an ingredient with unknown acute toxicity is used in a mixture at a concentration ≥ 1% and the mixture is not classified based on testing of the mixture as a whole, a statement that X% of the mixture consists of ingredient(s) of unknown acute toxicity is required. |
Section 3. Composition/information on ingredients. This section contains no new requirements other than format.
HCS 1994 | HCS 2012 |
· Chemical and common name of ingredients contributing to known hazards (g)(2)(i)(A), (B) · For untested mixtures, the chemical and common name of ingredients at 1% or more that present a health hazard and those that present a physical hazard in the mixture (g)(2)(i)(C)(1), (3) · Ingredients at 0.1% or greater, if listed carcinogens(g)(2)(i)(C)(2) |
3. Composition/information on ingredients Except as provided for in paragraph (i) of §1910.1200 on trade secrets: For Substances (a) Chemical name; (b) Common name and synonyms; (c) CAS number and other unique identifiers; (d) Impurities and stabilizing additives which are themselves classified and which contribute to the classification of the substance. For Mixtures In addition to the information required for substances: (a) The chemical name and concentration (exact percentage) or concentration ranges of all ingredients which are classified as health hazards in accordance with paragraph (d) of §1910.1200 and (1) are present above their cut-off/concentration limits; or (2) present a health risk below the cut-off/concentration limits. (b) The concentration (exact percentage) shall be specified unless a trade secret claim is made in accordance with §1910.1200(i), when there is batch-to-batch variability in the production of a mixture, or for a group of substantially similar mixtures (See A.0.5.1.2) with similar chemical composition. In these cases, concentration ranges may be used. For All Chemicals Where a Trade Secret is Claimed Where a trade secret is claimed in accordance with paragraph (i) of §1910.1200, a statement that the specific chemical identity and/or exact percentage of composition (concentration) has been withheld as a trade secret is required. |
Section 4. First-aid measures. This section contains no new requirements other than format.
HCS 1994 | HCS 2012 |
4. First-aid measures · Emergency and first-aid procedures (g)(2)(x) · Signs and symptoms of exposure (g)(2)(iv) |
(a) Description of necessary measures, subdivided according to the different routes of exposure, i.e., inhalation, skin and eye contact, and ingestion; (b) Most important symptoms/effects, acute and delayed. (c) Indication of immediate medical attention and special treatment needed, if necessary. |
Section 5. Fire-fighting measures. This section contains no new requirements other than format.
HCS 1994 | HCS 2012 |
· Physical hazards (potential for fire, explosion) (g)(2)(iii) · Emergency procedures(g)(2)(x) |
5. Fire-fighting measures (a) Suitable (and unsuitable) extinguishing media. (b) Specific hazards arising from the chemical (e.g., nature of any hazardous combustion products). |
Section 6. Accidental release measures. This section contains no new requirements other than format.
HCS 1994 | HCS 2012 |
· Procedures for cleanup of spills and leaks (g)(2)(viii) · Protective measures during maintenance and repair of contaminated equipment (g)(2)(viii) |
6. Accidental release measures (a) Personal precautions, protective equipment, and emergency procedures. (b) Methods and materials for containment and cleaning up. |
Section 7. Handling and storage. This section contains no new requirements other than format
HCS 1994 | HCS 2012 |
· Precautions for safe handling and use, including appropriate hygienic practices (g)(2)(viii) |
7. Handling and storage (a) Precautions for safe handling. Section 8. Exposure controls/personal protection. This section contains no new requirements other than format. |
HCS 1994 | HCS 2012 |
· General applicable control measures, such as appropriate engineering controls, work practices, and personal protective equipment (g)(2)(ix) · Protective measures during maintenance and repair of contaminated equipment (g)(2)(viii) · (g)(2)(ix) · Permissible exposure levels, threshold limit values, listed by OSHA, ACGIH, and other limit recommended or used by the MSDS preparer (g)(2)(vi) |
8. Exposure controls/personal protection (a) OSHA permissible exposure limit (PEL), American Conference of Governmental Industrial Hygienists (ACGIH) Threshold Limit Value (TLV), and any other exposure limit used or recommended by the chemical manufacturer, importer, or employer preparing the safety data sheet, where available. (b) Appropriate engineering controls. |
Section 9. Physical and chemical properties. This section contains no new requirements other than format.
HCS 1994 | HCS 2012 |
· Physical and chemical properties such as vapor pressure, flash point, etc. (g)(2)(ii) |
9. Physical and chemical properties (a) Appearance (physical state, color, etc.); (b) Odor; (c) Odor threshold; (d) pH; (e) Melting point/freezing point; (f) Initial boiling point and boiling range; (g) Flash point; (h) Evaporation rate; (i) Flammability (solid, gas); (j) Upper/lower flammability or explosive limits; (k) Vapor pressure; (l) Vapor density; (m) Relative density; (n) Solubility(ies); (o) Partition coefficient: n-octanol/water; (p) Auto-ignition temperature; (q) Decomposition temperature; (r) Viscosity. |
Section 10. Stability and reactivity. Although the information on conditions to avoid and hazardous decomposition products is new to HCS, it has been required in the ANSI Z400.1 standard for a number of years.
HCS 1994 | HCS 2012 |
· Physical hazards (potential for fire, explosion, reactivity) (g)(2)(iii) · Organic peroxides, pyrophoric, unstable(reactive), or water-reactive hazards (g)(2)(iii), definitions in (c) |
10. Stability and reactivity (a) Reactivity; (b) Chemical stability; (c) Possibility of hazardous reactions; (d) Conditions to avoid (e.g., static discharge, shock, or vibration); (e) Incompatible materials; (f) Hazardous decomposition products. |
Section 11. Toxicological information. This section contains no new requirements other than format.
HCS 1994 | HCS 2012 |
· Health hazards, including signs and symptoms of exposure, and any medical conditions which are generally recognized as being aggravated by exposure to the chemical (g)(2)(iv) · Primary routes of entry (g)(2)(iv) · Whether the hazardous chemical is listed in the National Toxicology Program (NTP) Report on Carcinogens (latest edition) or has been found to be a potential carcinogen in the International Agency for Research on Cancer (IARC) Monographs (latest editions), or by OSHA. (g)(2)(vi) |
11. Toxicological information Description of the various toxicological (health) effects and the available data used to identify those effects, including: (a) Information on the likely routes of exposure (inhalation, ingestion, skin and eye contact); (b) Symptoms related to the physical, chemical and toxicological characteristics; (c) Delayed and immediate effects and also chronic effects from short- and long-term exposure; (d) Numerical measures of toxicity (such as acute toxicity estimates). (e) Whether the hazardous chemical is listed in the National Toxicology Program (NTP) Report on Carcinogens (latest edition) or has been found to be a potential carcinogen in the International Agency for Research on Cancer (IARC) Monographs (latest editions), or by OSHA. |
Section 12. Ecological information (Non-mandatory). To be GHS-compliant the requirements for this section are provided.
HCS 1994 | HCS 2012 |
· No present requirements |
12. Ecological information (Non-mandatory) (a) Ecotoxicity (aquatic and terrestrial, where available); (b) Persistence and degradability; (c) Bioaccumulative potential; (d) Mobility in soil; |
Section 13. Disposal considerations (Non-mandatory). To be GHS-compliant the requirements for this section are provided, but OSHA will not enforce. However, OSHA may enforce provisions associated with safe handling and use, including appropriate hygienic practices. See Section 7 above.
HCS 1994 | HCS 2012 |
· See Section 7 · No present requirements |
13. Disposal considerations (Non-mandatory) Description of waste residues and information on their safe handling and methods of disposal, including the disposal of any contaminated packaging. |
Section 14. Transport information (Non-mandatory). To be GHS-compliant the requirements for this section are provided, but OSHA will not enforce.
HCS 1994 | HCS 2012 |
· No present requirements |
14. Transport information (Non-mandatory) (a) UN number; (b) UN proper shipping name; (c) Transport hazard class(es); (d) Packing group, if applicable; (e) Environmental hazards (e.g., Marine pollutant (Yes/No)); (f) Transport in bulk (according to Annex II of MARPOL 73/78 and the IBC Code); (g) Special precautions, which a user needs to be aware of, or needs to comply with, in connection with transport or conveyance either within or outside their premises. |
Section 15. Regulatory information (Non-mandatory). To be GHS-compliant the requirements for this section are provided, but OSHA will not enforce.
HCS 1994 | HCS 2012 |
· No present requirements |
15. Regulatory information (Non-mandatory) Safety, health and environmental regulations specific for the product in question. |
Section 16. Other information, including date of preparation or last revision. This section contains no new requirements other than format.
HCS 1994 | HCS 2012 |
· Date of preparation of MSDS or date of last change (g)(2)(xi) |
16. Other information, including date of preparation or last revision. The date of preparation of the SDS or the last change to it. |