Committee: SHERA

Results

This six-module course provides an in-depth examination of OSHA’s updated Hazard Communication Standards, which took effect in July 2024. The updated standards are designed to enhance workplace safety by ensuring employees understand chemical hazards and by strengthening protections through improved labeling requirements and higher-quality Safety Data Sheets (SDSs).

Ideal for regulatory, EHS, product stewardship, compliance, and technical staff who manage SDSs, labeling, or hazard communication programs.

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This course was made possible by members of ILMA’s SHERA Committee

  • Ann Ball, QualiChem
  • Robin Dilts, Quaker Houghton
  • Danielle Fish, RichardsApex
  • Donna Nijak, Hill & Griffith
  • Gwyn Rogers, Nelson Brothers
  • Tom Watson, Fuchs

Along with ILMA consultant John Howell and ILMA counsels Jeff Leiter and Jorge Roman

Questions? Contact Mary Schmitt, mschmitt@ilma.org.

Safety, Health, Environmental & Regulatory Affairs Committee Meeting

October 5, 2025

Boca Raton Resort, Boca Raton, FL

Safety, Health, Environmental & Regulatory Affairs Committee Meeting
Sunday, October 5, 2025
3:00 pm – 4:45 PM
Addison Ballroom
Boca Raton Resort, Boca Raton, FL

Our panel of experts highlighted major changes that will significantly affect members both as mixture manufacturers and as employers, while also sharing tips for compliance readiness.

Watch the Recording: https://www.youtube.com/watch?v=wCvD1ldci28

Key Takeaways

Compliance Deadlines Are Closer Than They Appear

  • Updates to SDSs, labels, etc.: Jan. 19, 2026 (substances) & July 19, 2027 (mixtures)
  • Updates to workplace labeling, written hazard communication programs and employee training: July 19, 2026 (substances) & Jan. 19, 2028 (mixtures)
  • Canada transitions sooner — Dec. 14, 2025

Downstream Hazards Must Be Considered

Manufacturers must account for downstream hazards from “known or reasonably anticipated” uses. Good practices include reviewing available data, engaging with software providers, considering proactive supply chain communication, documenting due diligence, and monitoring OSHA guidance.

Importantly, there is no requirement to conduct intensive downstream investigations, and it is essential to remember that the standard is hazard-based, not risk-based.

Classification Changes Matter

  • Health hazards: Incorporation of tiered data (in vitro/ex vivo) makes mixture classification more complex.
  • Physical hazards: Aerosols now have their own classification and category system; new classes added for desensitized explosives and chemicals under pressure.
  • SDSs: Trade secret concentration ranges are now prescribed and must be narrow.

Labeling Flexibility, But New Rules for Small Containers

  • No need to relabel products already released for shipment if new hazards emerge.
  • Small (≤100 mL) and very small (≤3 mL) containers may use reduced labeling, but outer packaging must include full details.

What You Can Do Now

  • Begin gathering updated SDSs from suppliers and documenting outreach.
  • Review your authoring software to ensure it will meet new requirements.
  • Consider developing separate U.S. and Canadian SDSs to avoid compliance conflicts.
  • Start employee training early — don’t wait until the deadlines.
  • Enroll your team in ILMA’s upcoming Hazard Communication Training Series for step-by-step guidance.
    Keep an eye out for an email announcement coming soon!

Will the EPR presentation used by David Lawes, Interchange360 be added to the 2025 SHERA slides? This was the first item on the agenda for discussion.

Thank you

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