By J. Darrel Hicks, Contributing Writer

Key Takeaways: 

• The revised OSHA standard strengthens the way chemical hazards are identified, communicated and managed. 
• The updates mean some familiar products might carry new or revised hazard categories, requiring managers to review safety data sheets carefully. 
• For managers, the most practical steps involve updating the written hazard communication program, revising workplace labels, retraining staff and auditing chemical inventories. 

The U.S. Occupational Safety and Health Administration (OSHA) issued a significant update to its hazard communication standard, 1910.1200 in May 2024, aligning it with the United Nations’ Globally Harmonized System of Classification and Labelling of Chemicals Revision 7. The rule took effect July 19, 2024, and introduced new hazard classifications, revised labeling requirements, updated safety data sheet formats and clearer guidance for small containers and bulk shipments. 

For healthcare facilities, environmental services (EVS), infection prevention and safety leaders, this update requires careful attention. Compliance is not optional. OSHA has set firm deadlines extending through 2028. 

At its core, the revised OSHA standard strengthens the way chemical hazards are identified, communicated and managed. Hospitals rely heavily on disinfectants, sterilants, laboratory reagents, maintenance chemicals and pharmaceuticals. Because these products fall under OSHA’s chemical hazard regulations, EVS managers must ensure their facilities transition smoothly to the new standard. 

The first major change involves hazard classification. OSHA has refined criteria for physical and health hazards, including flammable gases, aerosols, skin and eye irritation, and chemicals under pressure. OSHA added a new hazard class — desensitized explosives — though it is unlikely to affect most healthcare settings. Importantly, OSHA now recognizes certain non-animal test methods for determining health hazards in order to reflect modern scientific practices. These updates mean some familiar products might carry new or revised hazard categories, requiring managers to review safety data sheets carefully. 

Labeling requirements also have been strengthened. The rule clarifies the way manufacturers and employers must label small containers, including those under 100 mL and 3 mL — sizes commonly used in hospitals for reagents, cleaning solutions and secondary containers. Bulk shipments, such as large disinfectant totes, now have more flexible labeling options, but managers must ensure that workplace labels remain accurate and accessible to employees. 

Safety data sheets will undergo notable changes as well. Sections 2, 3, 9, and 11 must reflect updated hazard classifications, physical properties, and toxicological information. OSHA also now permits concentration ranges for ingredients when trade secrets are involved, but the ranges must follow strict guidelines. Managers should begin requesting updated safety data sheets from suppliers immediately, as manufacturers face compliance deadlines in 2026 and 2027. 

For managers, the most practical steps involve updating the written hazard communication program, revising workplace labels, retraining staff and auditing chemical inventories. EVS teams, nursing units, laboratories, pharmacy departments and facilities personnel must understand new pictograms, signal words, precautionary statements and hazard categories. Training must be completed before employer deadlines — November 2026 for substances and May 2028 for mixtures. 

Finally, coordination between EVS, infection prevention and safety departments is essential. Updated safety data sheets might affect personal protection equipment requirements, storage practices, spill response procedures and emergency planning. Accreditation bodies such as Joint Commission and DNV will expect documentation to demonstrate compliance. 

OSHA’s updated hazard communication standard represents the most substantial change to chemical communication requirements in nearly a decade. By acting now and reviewing safety data sheets, updating labels, revising programs and retraining staff — hospital managers can ensure a safer environment for workers and patients while meeting regulatory expectations. 

J. Darrel Hicks, BA, MESRE, CHESP, Certificate of Mastery in Infection Prevention, is the past president of the Healthcare Surfaces Institute. Hicks is nationally recognized as a subject matter expert in infection prevention and control as it relates to cleaning. He is the owner and principal of Safe, Clean and Disinfected. His enterprise specializes in B2B consulting, webinar presentations, seminars and facility consulting services related to cleaning and disinfection. He can be reached at darrel@darrelhicks.com, or learn more at www.darrelhicks.com.