By: Kevin Mouser


Kevin Mouser has a Bachelor's degree in Biology from the University of Indianapolis and is a certified Hazardous Materials Manager. Kevin has served as the Environmental Manager since 1990.

E-mail Kevin Mouser at: kmouser@iupui.edu



Hazard Communication System Revisions Update

In the Spring 2011 edition of Lab Notes, we discussed proposed changes to the Hazard Communication Standard (HCS), commonly known as the Worker Right-to-Know standard.  Specifically, the U.S. Occupational Safety and Health Administration (OSHA) was proposing to adopt major portions of an existing international hazard communication system known as the Globally Harmonized System (GHS).


On March 26, 2012, OSHA formally modified the existing HCS making the standard consistent with the GHS.  Major changes to the existing standard include:


Hazard Classification: Chemical manufacturers and importers are required to determine the hazards of the chemicals they produce or import. Hazard classification under the new, updated standard provides specific criteria to address health and physical hazards as well as classification of chemical mixtures.


Labels: Chemical manufacturers and importers must provide a label that includes a signal word, pictogram, hazard statement, and precautionary statement for each hazard class and category.


Safety Data Sheets: The new format requires 16 specific sections, ensuring consistency in presentation of important protection information.


Information and training: To facilitate understanding of the new system, the new standard requires that workers be trained by December 1, 2013 on the new label elements and safety data sheet format, in addition to the current training requirements.


Following are key compliance dates for the revised HCS: 


Effective Completion Date



December 1, 2013

Train employees on the new label elements and safety data sheet (SDS) format.


June 1, 2015*
December 1, 2015

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

Chemical manufacturers, importers, distributors and employers

June 1, 2016

Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards.


Transition Period to the effective completion dates noted above

May comply with either 29 CFR 1910.1200 (the final standard), or the current standard, or both

Chemical manufacturers, importers, distributors, and employers


While the revised HCS does not supersede the OSHA Laboratory Standard, campus laboratory workers will need to become familiar with the revised standard as labeling and material safety data sheets (soon to be commonly known as Safety Data Sheets) will be affected.


Something new for those familiar previously with the HCS will be the use of the following hazard pictograms. 


Health Hazard
Description: Health Pictogram

Reproductive Toxicity
Respiratory Sensitizer
Target Organ Toxicity
Aspiration Toxicity

Description: Health Pictogram

Emits Flammable Gas
Organic Peroxides

Exclamation Mark
Description: Health Pictogram

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

Gas Cylinder
Description: Health Pictogram

Gases Under Pressure

Description: Health Pictogram

Skin Corrosion/Burns
Eye Damage
Corrosive to Metals

Exploding Bomb
Description: Health Pictogram

Organic Peroxides

Flame Over Circle
Description: Health Pictogram


Description: Health Pictogram

Aquatic Toxicity

Skull and Crossbones
Description: Health Pictogram

Acute Toxicity (fatal or toxic)

An excellent resource on the revised HCS can be found at this link: http://www.osha.gov/dsg/hazcom/index.html


Lab Notes is a quarterly publication by the IUPUI Office of Environmental Health and Safety. Lab Notes is designed, edited and published by K. Lee Stone.

"Don't Learn Laboratory Safety by Accident!"