The Clock Is Ticking: 8 Months to November 20
The HazCom 2024 final rule gave employers until November 20, 2026 to fully transition to GHS Revision 7. That's roughly 8 months from today.
Based on our analysis of thousands of HazCom programs, most employers are behind. Here are the 7 updates you need to make before Q3 to stay on track.
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Update #1: Add the New Hazard Classes to Your Written Program
GHS Revision 7 introduces hazard classes that didn't exist in prior revisions. Your written HazCom program must reference them:
New Hazard Classes
| Hazard Class | What It Covers | Example Chemicals |
|-------------|----------------|-------------------|
| Chemicals Under Pressure | Gases/liquids packaged under pressure (not compressed gas) | Aerosol propellants, pressurized solvents |
| Desensitized Explosives | Explosives diluted/wetted to suppress explosive properties | Wetted TNT, phlegmatized explosives |
| Aerosols (reclassified) | Expanded from 2 to 3 categories | Spray paints, adhesive sprays |
| Flammable Gases (updated) | New sub-categories for pyrophoric and chemically unstable gases | Silane, diborane |
Action item: Open your written program and add a section acknowledging these classes. If any chemical in your inventory falls into these categories, document the specific controls.
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Update #2: Audit Your SDS Library for Currency
GHS Rev 7 requires manufacturers and importers to update their SDSs. That means:
How to Audit
1. Export your chemical inventory list
2. For each chemical, check the SDS revision date
3. If the SDS is older than January 2025, contact the manufacturer for an updated version
4. Flag any chemicals that now fall into new Rev 7 hazard classes
Use the **[SDS Gap Analyzer](/t