OSHA HazCom 2024 / GHS Revision 7 Deadlines: SDS and Secondary Labels

Frequently Asked Questions

Do all employers have to meet the HazCom 2024 deadline at the same time?

No. OSHA set staggered compliance dates, with manufacturers, importers, and distributors transitioning before downstream employers. Site employers still need to prepare early because revised SDSs and labels will arrive over time.

What has to be on a secondary chemical container label?

For workplace secondary containers, OSHA requires the chemical identity and general hazard information in a form employees can understand. The label must be legible and tied clearly to the specific chemical in the container.

Is a label required for a container used immediately by one employee?

Not in the narrow immediate-use situation described in the article. Outside that exception, secondary containers need workplace labeling.

Why is an SDS library update so important under the GHS Revision 7 transition?

Because outdated SDSs can break the link between purchasing, labeling, training, and emergency response. A current, searchable SDS library helps ensure employees and supervisors are using the right hazard information.

Do trade-secret SDSs still have to provide hazard information?

Yes. Trade-secret protections do not remove the obligation to communicate the hazard and protective information workers and medical personnel need for safe use and response.