Modification of the Hazard Communication Standard (HCS)

Modification of the Hazard Communication Standard (HCS) to conform with the United Nations’ (UN) Globally Harmonized System of Classification and Labeling of Chemicals (GHS)

Hazard Communication Standard (HCS)


The Globally Harmonized System (GHS) is an international approach to hazard communication, providing agreed criteria for classification of chemical hazards, and a standardized approach to label elements and safety data sheets. The GHS was negotiated in a multi-year process by hazard communication experts from many different countries, international organizations, and stakeholder groups. It is based on major existing systems around the world, including OSHA’s Hazard Communication Standard and the chemical classification and labeling systems of other US agencies. There are nine pictograms under the GHS to convey the health, physical and environmental hazards. The final Hazard Communication Standard (HCS) requires eight of these pictograms, the exception being the environmental pictogram, as environmental hazards are not within OSHA’s jurisdiction. The hazard pictograms and their corresponding hazards are shown below. Reference:


Health Hazard


  • Carcinogen
  • Mutagenicity
  • Reproductive Toxicity
  • Respiratory Sensitizer
  • Target Organ Toxicity
  • Aspiration Toxicity




  • Flammables
  • Pyrophorics
  • Self-Heating
  • Emits Flammable Gas
  • Self-Reactives
  • Organic Peroxides


Exclamation Mark


  • Irritant (skin and eye)
  • Skin Sensitizer
  • Acute Toxicity (harmful)
  • Narcotic Effects
  • Respiratory Tract Irritant
  • Hazardous to Ozone Layer
  • (Non Mandatory)


Gas Cylinder


  • Gases under Pressure




  • Skin Corrosion/ burns
  • Eye Damage
  • Corrosive to Metals


Exploding Bomb


  • Explosives
  • Self-Reactives
  • Organic Peroxides


Flame over Circle


  • Oxidizers


Environment (Non Mandatory)


  • Aquatic Toxicity


Skull and Crossbones


  • Acute Toxicity (fatal or toxic)


The phase-in period for the revised Hazard Communication Standard:

The table below summarizes the phase-in dates required under the revised Hazard Communication Standard (HCS):

Effective Completion Date: December 1, 2013.
Requirement(s): Train employees on the new label elements and safety data sheet (SDS) format.
Who: Employers.

Effective Completion Date: June 1, 2015*
Requirement(s): Compliance with all modified provisions of this final rule, except:
Who: Chemical manufacturers, importers, distributors and Employers.

*This date coincides with the EU implementation date for classification of mixtures.
During the phase-in period, employers would be required to be in compliance with either the existing HCS or the revised HCS, or both. OSHA recognizes that hazard communication programs will go through a period of time where labels and SDSs under both standards will be present in the workplace. This will be considered acceptable, and employers are not required to maintain two sets of labels and SDSs for compliance purposes.

Effective Completion Date: December 1, 2015.
Requirement(s): Compliance with all modified provisions of this final rule, except:
The Distributor shall not ship containers labeled by the chemical manufacturer or importer unless it is a GHS label.
Who: Employers.

Effective Completion Date: June 1, 2016.
Requirement(s): Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards.
Who: Employers.

Effective Completion Date: Transition Period to the effective completion dates noted above.
Requirement(s): May comply with either 29 CFR 1910.1200 (the final standard), or the current standard, or both.
Who: Chemical manufacturers, importers, distributors, and employers.

**Accessibility Assistance: Contact OSHA’s Directorate of Standards and Guidance at (202) 693-1950 for assistance accessing DOC, EPS, GIF, MP4, PDF, PPT or XLS documents.

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