OSHA Clarifies HazCom Rules: Aerosols Are Not Gases Under Pressure
What Changed
OSHA has updated Table B.5.1 in Appendix B of the Hazard Communication Standard (HazCom 2012/GHS) to clarify that aerosols and chemicals under pressure should not be classified as gases under pressure. The update addresses a longstanding source of confusion in chemical hazard classification.
Previously, many manufacturers and importers classified aerosol products under both the "Aerosols" category and the "Gases Under Pressure" category. This dual classification triggered additional label elements — pictograms, signal words, and hazard statements — that were redundant and potentially misleading.
Why It Matters
Over-classification has real consequences. When an aerosol can carries the same gas cylinder pictogram as a high-pressure industrial gas cylinder, it dilutes the warning. Workers may become desensitized to hazard labels, and safety data sheets become cluttered with inapplicable precautionary statements.
The clarification means:
- Fewer redundant label elements on aerosol products — reducing label clutter
- Clearer hazard communication — the gas cylinder pictogram is reserved for actual compressed, liquefied, or dissolved gases
- Simpler SDS authoring — Section 2 (Hazards Identification) no longer needs dual classification language for aerosols
Compliance Timeline
Manufacturers, importers, and distributors evaluating substances and mixtures must comply with all modified provisions of the updated HazCom standard by May 19, 2026. That deadline applies to this clarification along with other updates from the 2024 HazCom revision.
Companies that have already updated their labels and SDSs to reflect the dual classification should review and remove the "Gases Under Pressure" classification from aerosol and chemicals-under-pressure products before the deadline.
What to Do
If your organization manufactures, imports, or relabels chemical products:
- Audit your product classifications — Identify any aerosol or chemical-under-pressure products currently classified as "Gases Under Pressure"
- Update SDSs and labels — Remove the gas cylinder pictogram (GHS04) and associated hazard statements from aerosol products
- Train your team — Make sure EHS and hazard classification staff understand the distinction
- Document the change — Keep records of the reclassification for compliance audits
Alliance's Take
This is a welcome clarification from OSHA. Accurate hazard classification is the backbone of chemical safety, and over-labeling can be just as problematic as under-labeling. When every product carries the same pictograms, workers stop paying attention to them.
Alliance Chemical provides current, compliant Safety Data Sheets in our document library — ask us and we will send the one you need. As HazCom requirements evolve, we update our documentation to reflect the latest OSHA guidance. If you need SDS documents, Certificates of Analysis, or technical data sheets for any of our products, ask us and we will send them at no charge.
Questions about product classification or compliance documentation? Contact us at sales@alliancechemical.com.
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Frequently asked questions
How does the updated OSHA HazCom standard affect aerosol classification?
Under the updated OSHA HazCom 2012/GHS standard, aerosols and chemicals under pressure are no longer classified as gases under pressure. This change to Table B.5.1 in Appendix B eliminates redundant labeling. Manufacturers must remove the gas cylinder pictogram and associated hazard statements from aerosol products to ensure clearer hazard communication for workers.
What is the compliance deadline for the new OSHA aerosol labeling rules?
Organizations must comply with the modified HazCom provisions, including the aerosol classification update, by May 19, 2026. This deadline requires manufacturers, importers, and distributors to have updated their Safety Data Sheets and product labels. Any products currently carrying dual classifications should be reviewed and corrected before this date to maintain regulatory compliance.
Why did OSHA remove the gas cylinder pictogram requirement for aerosol products?
OSHA removed the requirement to prevent over-classification and label clutter. Previously, dual classification forced the use of the gas cylinder pictogram on aerosols, which diluted warnings for high-pressure industrial cylinders. By reserving the pictogram for actual compressed or liquefied gases, OSHA ensures that hazard communication remains effective and that workers do not become desensitized to safety labels.
What steps should companies take to comply with the updated HazCom aerosol rules?
Companies should begin by auditing current product classifications to identify aerosols incorrectly labeled as gases under pressure. Safety Data Sheets and labels must be updated to remove the GHS04 pictogram and redundant hazard statements. Additionally, environmental health and safety staff should be trained on these distinctions, and all reclassification actions should be documented for future audits.
About the author
Andre Taki
This article is for informational purposes only.