ILMA Calls for Regulatory Clarity and Relief for HCS 2024
ILMA has joined a broad coalition of trade associations and industry groups in submitting a letter to Secretary Lori Chavez-DeRemer of the U.S. Department of Labor, urging targeted relief and implementation support for OSHA’s 2024 revisions to the Hazard Communication Standard (HCS). While the changes aim to align the standard with the Globally Harmonized System (GHS), they raise significant compliance challenges for stakeholders that depend on upstream suppliers and complex supply chains. ILMA collaborated with the coalition to highlight the unique perspective of lubricant manufacturers.
Main Challenges
The HCS 2024 introduces new requirements that significantly affect how ILMA members author and rely on Safety Data Sheets (SDSs), particularly in cases involving:
- Hazard classification based on “reasonably anticipated uses or applications” of chemical substances and mixtures downstream.
- Compressed compliance timelines that fail to account for the regular flow of information and upstream supply chain dependencies, leaving formulators with limited time to revise SDSs and classify hazards.
Without clear guidance and reasonable flexibility, lubricant manufacturers face challenges in meeting compliance obligations in good faith. ILMA emphasized an example in the coalition letter:
“Mixture manufacturers receiving mixtures (e.g., a lubricant manufacturer receiving additive packages or blends for formulation) may encounter classification challenges, in addition to Section 2 hurdles, when authoring compliant SDSs without updated SDSs from mixture suppliers,” the letter states.
Coalition Recommendations
The coalition letter requests that OSHA:
- Issue implementation guidance to clarify how manufacturers should exercise discretion in determining “reasonably anticipated” hazards downstream.
- Establish enforcement discretion to provide phased enforcement relief for entities that rely on information from suppliers to meet HCS 2024 requirements, including lubricant manufacturers that receive mixtures for formulation.
- Publish HCS 2012 and 2024 redline comparison to facilitate understanding of the changes.
Next Steps
ILMA continues to advocate for practical implementation of the HCS to ensure compliance is achievable—without creating undue burdens for lubricant manufacturers. As part of the coalition, the Association will seek to meet with regulators to elaborate on some of the challenges outlined in the coalition letter. We urge members to stay engaged as we work with OSHA to develop implementation guidance and policy relief.
“Lubricant manufacturers—key stakeholders in HazCom regulation—are committed to safety, but they need practical, achievable compliance pathways. That’s why ILMA is advocating for clear guidance and flexibility, while also developing training modules to support our members every step of the way,” said ILMA CEO Holly Alfano.
Read more about HCS 2024 in the July/August 2025 issue of Compoundings.