Per the Occupational Safety and Health Administration (OSHA), employers must comply with the updated requirements of the Hazard Communication (HazCom) Standard [29 CFR 1910.1200] for chemical substances used in the workplace by November 20, 2026. The compliance deadline for mixtures is May 19, 2028.
The revised HazCom Standard, published in 2024, aligns U.S. regulations with the seventh revision of the United Nations’ Globally Harmonized System of Classification and Labelling of Chemicals (GHS). The changes are intended to improve the quality and consistency of chemical hazard information provided to workers, employers, first responders, and downstream users.
HazCom Standard Updates
The revised Standard includes the following changes:
- Amended hazard classification requirements: Manufacturers and importers must now consider hazards associated with a chemical’s intrinsic properties, including those resulting from changes in physical form and from chemical reaction products associated with known or reasonably anticipated uses.
- New hazard class: The distinct ‘desensitized explosives’ hazard classification was created to better understand and communicate the potential risks attributed to these solid and liquid materials.
- New hazard categories: The revised rule adds chemicals under pressure within the aerosols hazard class and unstable gases within the flammable gases class.
- Revised health (Appendix A) and physical (Appendix B) hazard criteria: OSHA updated several hazard definitions and classification criteria such as those related to skin corrosion and irritation, serious eye damage and eye irritation, flammable gases, and aerosols.
- Safety data sheet (Appendix D) updates: Section 9 of the SDS, Physical and Chemical Properties, must now present information in a specified order. For solid materials, particle characteristics must also be disclosed.
- Trade secret provisions: Manufacturers claiming trade secret protections for ingredient composition must now select the narrowest applicable concentration range from OSHA’s prescribed options and provide it on the SDS.
- Updated pictogram uses: The revised Standard requires the use of the flame pictogram for desensitized explosives and the optional use of the exclamation mark pictogram for hazards not otherwise classified (HNOC).
- Changes to precautionary statements: Several precautionary statements have been reworded and new ones added to provide updated guidance on the safe handling, storage, and disposal of hazardous chemicals.
- Supplier information: Supplier information on labels and SDSs must now provide a U.S. address and phone number.
What Employers Should Do Before November 20, 2026
The deadline for manufacturers, importers, and distributors to update SDSs and shipped-container labels for chemical substances was May 19, 2026. For mixtures, the deadline will be November 19, 2027. As new hazard information becomes available, employers should take the following steps to ensure compliance before the November 20, 2026 deadline.
- Maintain the latest SDSs: SDSs dated before May 19, 2026, may not reflect the revised hazard classifications and other required updates. Review your SDS library to ensure it is current and retain the most recent SDS version as new chemical orders are received. Applicable SDSs must be readily available to employees, and outdated versions should be archived and kept for at least 30 years.
- Verify workplace labels/signage: Modifications to hazard classification criteria may have resulted in changes to pictograms, signal words, hazard statements, and/or precautionary statements on incoming product labels. Ensure that door and area signage, as well as workplace container labels, accurately reflect the most current hazard information for the chemicals in use.
- Update your written program(s): Review and revise your written Hazard Communication Program to incorporate the amended classification criteria, SDS management procedures, as well as the labeling and employee training requirements. If you fall under the Occupational Exposure to Hazardous Chemicals in Laboratories Standard [29 CFR 1910.1450], commonly referred to as the Lab Standard, the Chemical Hygiene Plan will need to be checked and modified as necessary. Please note, depending on your organization’s needs, both documents may apply.
- Train employees: Employees must be informed and trained on any newly identified physical or health hazards, changes to existing hazard classifications, revised label elements, and updated SDS information for the chemicals they use or may be exposed to in the workplace. Training should be completed and documented before the mandatory due date.
Need Help Complying?
With the November 20, 2026, deadline quickly approaching, now is the time to evaluate your overall Hazard Communication Program. Reviewing SDSs, updating workplace labels, revising written programs, and providing employee training can help improve worker safety and regulatory compliance.
For additional information about the revised Hazard Communication Standard and its impact on your organization, check out our 2024 Updates to the HazCom Standard: What You Should Know blog, our Revised Hazard Communication Standard Compliance Deadlines! blog, or contact us. We can help assess how the updated regulation applies to your operations and provide assistance with SDS management, workplace signs and labeling, HazCom program changes, and employee training.
This blog was written by Beth Graham, Director of Quality, Research, and Training at Safety Partners.
