Ever since OSHA published the revised Hazard Communication Standard (HCS), employers have had questions regarding container labeling. The revised HCS, which OSHA refers to as “HCS 2012” to distinguish it from the prior rule referred to as “HCS 1994,” significantly impacts labeling requirements for containers of hazardous chemicals.

The HCS requires that those most familiar with the hazards of the chemical — the companies that produce, import or distribute them — assess the hazards and convey this information to downstream users.