In 2021, the US Occupational Safety and Health Administration published a Notice of Proposed Rulemaking (NPRM) in the Federal Register that would largely align US hazard communication regulations with UN GHS Revision 7. Two years later, in mid-2024, US-OSHA finalized the rule, but allowed for transition periods in updating safety data sheets and labels:
For manufacturers, importers, and distributors:
For substances, update SDSs and labels by January 19, 2026.
For mixtures, update SDSs and labels by July 19, 2027.
For employers:
For substances, update employee training, workplace labels, and hazard communication programs by July 20, 2026.
For mixtures, update employee training, workplace labels, and hazard communication programs by January 19, 2028.
Those of you who create SDSs and labels for the US market may be in the process of updating these items for the new standard.
Here are some update suggestions for revising existing SDSs:
You can make a copy of an existing SDS in the SDS browse list, by right-clicking on the existing SDS, and selecting “Duplicate this SDS” from the contextual menu.
Double-click on the duplicate SDS to edit it.
On the “2 Hazards” tab, change the GHS version to “US21”. This is the program’s reference to the OSHA 2024 standard. The program will ask you to confirm that you want to change the “Classification according to…” statement to “[US] OSHA (29 CFR 1910.1200, 2024). It will also offer to revise any existing classifications, hazard statements, and precautionary statements as needed to reflect revised wording for the GHS revision. You should confirm both of these requests.
If any of the SDSs represent flammable gases, desensitized explosives, aerosols, or other chemicals under pressure, you may want to re-evaluate these products for additional classifications using updated criteria from the final rule.
You can use prescribed concentration ranges (“3 Composition” tab, “Min% dsp” column), to appear on the SDS in place of the actual component concentrations, if you wish to claim trade secrecy. The range that you select should include the actual concentration value. You should also include a statement to this effect, in the “Trade secret statement…” area below the Component table.
On the “16 Other” tab of the SDS entry form, update the Version field contents. You may also want to enter information into the Revision, Supersedes, Issued on, and/or Print date fields.
Duplicating an existing safety data sheet in the SDS browse list, by right-clicking on it to select from the contextual menu.
Changing an SDS from the GHS version “US” to the GHS version “US21”, for US-OSHA 2024 compatibility.
Selecting a prescribed concentration range for a product component, which will appear on the generated SDS in place of an actual concentration. In the Component table, “3 Composition” tab. The range you select should always include the actual concentration.