Heads up! HazCom employer compliance deadline approaching fast

OSHA’s revised Hazard Communication (HazCom) standard contains multiple compliance dates at 29 CFR 1910.1200 paragraph (j) for chemical manufacturers, importers, distributors, and employers. In fact, the next compliance date is for employers, and it’s just over two months away! The November 20, 2026, employer deadline is driven by changes to chemical hazard classifications for aerosols, desensitized explosives, and flammable gases.

Reclassification impacts downstream chemical users

According to 1910.1200(j), chemical manufacturers, importers, and distributors evaluating substances (see the definition in 1910.1200(c)) based on the new classifications had until May 19, 2026, to:

• Reclassify the substances under revised criteria,
• Update their safety data sheets (SDSs) and shipping labels for these substances, and
• Otherwise be in compliance with all the modified provisions of the standard for those substances. 

Hazard classification is the process of identifying a chemical’s hazards and determining how severe those hazards are. Chemical manufacturers and importers use 1910.1200(d), along with Appendix A (for health hazards) and Appendix B (for physical hazards) to make these determinations. When OSHA aligned HazCom with Revision 7 of the Globally Harmonized System of Classification and Labeling (GHS) in 2024, the agency revised its classification categories for aerosols, desensitized explosives, and flammable gases.

Once a classification is determined, it dictates the warnings, pictograms, hazard statements, and other safety and health information that must appear on SDSs and shipping labels. OSHA explains that the classification should provide downstream users with sufficient information to perform a hazard assessment specific to their own workplace and to understand how employees must use the chemical product there.

How the November 20 deadline impacts employers

Employers who purchase substances that are aerosols, desensitized explosives, and flammable gases will receive (or may already have received) revised SDSs and see updated container labels with their shipments. 

In addition, according to 1910.1200(j), all employers must, as necessary:

• Update any alternative workplace (in-house) labeling per 1910.1200(f)(6);
• Update their HazCom training program required by 1910.1200(h)(1); and
• Provide additional employee training in line with 1910.1200(h)(3) for newly identified physical, health, or other hazards covered by the standard.

Employers will also need to retain any new SDSs they receive. However, if they have not purchased new inventory, they’re not required to contact the manufacturer, importer, or distributor for a new SDS. Still, an employer may proactively request new ones from their suppliers anyway.

Further HazCom compliance dates in paragraph (j)

Chemical manufacturers and, importers, and distributors evaluating mixtures (as defined in 1910.1200(c)) based on the new classifications have until November 19, 2027, to reclassify them based on the new criteria, update their SDSs and shipping labels, and otherwise be in compliance with all the modified provisions of the standard for those mixtures.

Also, for mixtures, employers have until May 19, 2028, to update any alternative workplace labeling, update their HazCom training program, and provide additional employee training for newly identified physical, health, or other hazards.