OSHA HCS Update – Impact on Labeling

Jan 31, 2024

A highly anticipated update to the OSHA Hazard Communication Standard (29 CFR 1910.1200) may be getting close to realization. OSHA sent the final rule to the Office of Management & Budget (OMB) for review as the final step before the new rule is published.

The stated purpose of the update is to “maintain conformity with the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS) (revision 7), align certain provisions with Canada and other U.S. agencies, and address issues that have developed since implementation of the 2012 standard.”¹

The proposed rule was promulgated almost three years ago² and has gone through an extended review and comment period with much debate concerning the anticipated impacts of the new rule. The impact of the final rule on labeling is significant. When regulatory content on a label changes, the label content must be updated and re-printed. It renders production labels immediately obsolete, notwithstanding whatever the phase-in implementation period is for the updated rule.

It’s difficult to estimate the scope of this impact on the chemical industry as a whole, including manufacturers, distributors, blenders, packagers, transporters and many other stakeholders along the value chain from origin to end-use consumer. The reality is that hundreds of thousands of individual label “sku’s” must be changed and the labels re-printed – literally millions of labels. While the stated purpose of the update is desirable; to “increase worker protections and reduce the incidence of chemical-related occupational illnesses and injuries by further improving the information on labels and safety data sheets (SDS) for hazardous chemicals”³, the desired benefits are not without cost.

Effected businesses must assess the impact, in terms of the effort and cost of complying with the updated rule, as well as risks to their business other than the obvious risks of non-compliance. Regulatory change brings with it the risk of potential disruption to their manufacturing and distribution operations as their labels are changed, re-printed and moved into production. The more label “sku’s” a company has that are required to change, the greater the risk, cost and overall impact.

A proven way to help mitigate the risks and impact of frequent regulatory changes on labeling as described above is to adopt an “on-demand” process of labeling. The essential ingredients of an on-demand labeling process are:

  • Label design and management software that enables rapid design, “on the fly” maintenance and immediate implementation.
  • A local, “on-premise” digital label printing platform.
  • Blank, rather than pre-printed label stock.

A digital, on-premise, on-demand labeling solution that includes these three ingredients has significant advantages that help to mitigate the effect of frequent “regulatory churn”:

  • Allows labels to be printed “on-demand” – at the exact time they are needed, in the exact quantity needed, in the exact location they are needed.
  • Eliminates burdensome minimum order quantities of pre-printed labels.
  • Eliminates waste as pre-printed labels must be thrown away due to obsolescence.
  • Eliminates long lead times and extra cost associated with re-printing pre-printed labels.
  • Reduces potential disruption to production and distribution operations caused by an interruption in the availability of printed labels.

The adoption and implementation of digital, on-premise, on-demand label printing gives businesses a proven strategy to exert control over the risk factors associated with frequent regulatory changes, whether it’s the OSHA HCS, California Prop 65 or any of the constantly expanding array of regulatory compliance requirements at every level of jurisdiction.

At Brandywine Label Printing, we partner with our customers to recommend, design and implement the right print-on-demand labeling solution that meets their specific requirements. Contact us to learn how you can take control over your labeling process and effectively mitigate the risks associated with frequent regulatory change.


¹ U.S. Department of Labor, Occupational Safety and Health Administration

² Federal Register/Vol. 86, No. 29/Tuesday, February 16, 2021/Proposed Rules

³ U.S. Department of Labor, Occupational Safety and Health Administration