In May 2024, the Department of Labor published the Final Rule of the Occupational Safety and Health Administration’s (OSHA) updated Hazard Communication (HazCom) Standard [29 CFR 1910.1200]. The revised standard is aligned with the seventh revision of the United Nations’ Globally Harmonized System of Classification and Labelling of Chemicals (GHS).
Although the updated standard was effective in July 2024, the first deadline for full compliance was January 19, 2026. However, on January 15, 2026, OSHA announced in the Federal Register that this deadline has been extended by four months to May 19, 2026. For mixtures, the date is now November 19, 2027. These compliance deadlines apply to manufacturers, importers, and distributors of chemical substances.
Employer compliance deadlines were also extended by four months (November 20, 2026 for chemical substances and May 19, 2028 for mixtures).
According to the Agency, the revised dates allow OSHA more time to finalize and publish guidance documents about the updated HazCom Standard and for the regulated community to review the materials to comply with it.
Manufacturer, Importer, and Distributer Compliance Requirements
The revised version of the HazCom Standard has new requirements for manufacturers, importers, and distributors including the following:
- Evaluate the health hazards of chemicals based on updates to Appendix A – Health Hazard Criteria, which includes new health hazard definitions and revisions to some sections, including those on skin corrosion/irritation and serious eye damage/irritation.
- Determine the physical hazards of chemicals according to the updates in Appendix B – Physical Hazard Criteria, which now contains an additional hazard class (desensitized explosives) and new hazard categories, including chemicals under pressure within the aerosols class, and unstable gases in the flammable gases class.
- Incorporate hazards associated with a chemical’s intrinsic properties when conducting a hazard evaluation, including a change in the physical form as well as chemical reaction products associated with known or reasonably anticipated uses or applications.
- Address provisions related to trade secrets to help ensure they don’t prevent workers and first responders from receiving hazard information. They include disclosing the concentration range of trade secrets based on a prescribed list of range options and including the narrowest range on the safety data sheet (SDS).
- Update pictograms as applicable. This includes using the flame pictogram for desensitized explosives and the option to use the exclamation point pictogram for hazards not otherwise classified (HNOC).
- Use revised precautionary statements (included in Appendix C – Allocation of Label Elements) on how to safely handle, store, and dispose of hazardous chemicals. Some have been updated for existing hazard classes and others were added for new and revised hazard classes.
- Revise SDSs and labels based on the updated Standard requirements noted above. In addition, modify the content of SDSs as required, including the addition of particle characteristics for solid products in Section 9 and information on hazardous reactions associated with foreseeable emergencies in Section 10.
- Address the new labeling provisions for small containers (100 mL or less) that allow for the use of an abbreviated version of shipped container label information, and for very small containers (3 mL or less) which, in some cases, will only require a product identifier.
Employer Compliance Requirements
Because the final rule will require manufacturers, distributors, and importers to reclassify the physical, health, and other hazards of some chemicals, as well as incorporate new SDS requirements, they will be providing downstream users/employers with revised SDSs. In addition, in some cases, chemicals will require updated labels, so end users can expect to receive some chemicals that have new labels.
Before November 2026, employers that receive chemicals covered by the HazCom Standard will need to come into compliance. This will involve meeting these requirements:
- Maintain newly received updated SDSs and archive older versions.
- Incorporate updated label hazard classifications on workplace/in-house labels.
- Update the facility’s written Hazard Communication Program and training as needed to include any newly identified physical, health, or other hazards associated with the chemicals used onsite.
For additional information on the Hazard Communication Standard final rule and how the changes might affect your organization, check out our 2024 Updates to the HazCom Standard: What You Should Know blog or contact us! We can help determine how the updated Regulation applies to you, when you must come into compliance, and assist with updating your HazCom program and training.
This blog was written by Beth Graham, Safety Partners’ Director of Quality, Research, and Training.
