OSHA has issued a final rule, extending the compliance deadlines set in the agency’s 2024 amendments to the Hazard Communication Standard (HCS).

In HCS 2024, OSHA established a tiered compliance schedule setting different deadlines for chemical manufacturers, importers and distributors of substances and mixtures, as well as employers.

As the first major compliance deadline approaches—January 19, 2026—for chemical manufacturers, importers and distributors of substances, OSHA decided that a four-month extension is appropriate because the agency is still preparing compliance guidance.

OSHA explains: “Although OSHA has been working to finalize key guidance about the updated HCS for both the regulated community and agency personnel, the agency has not been able to complete these documents with sufficient time for the regulated community and OSHA personnel to benefit from them before the initial compliance date.”

OSHA guidance will address key aspects of the amended standard, including hazard classification, labeling and safety data sheets (SDSs). Of particular interest to industry stakeholders, the agency will provide guidance on the due diligence required to classify downstream “known or reasonably anticipated” hazards.

To preserve the tiered structure adopted in the final rule, OSHA is also extending all subsequent compliance deadlines applicable to mixtures and employers by the same four-month period. Importantly for lubricant manufacturers, now the deadline for updating labels and SDSs for mixtures is November 19, 2027. The new compliance schedule is:

Until the now-extended compliance dates, regulated parties may follow the 2012 version of the HCS, the 2024 version, or both.

ILMA will continue to monitor the release of updated HCS guidance materials and advocate for enforcement relief, particularly for mixtures, which remain a significant compliance challenge for lubricant manufacturers. Mixture suppliers may not provide complete or updated hazard information sufficiently in advance of the new compliance deadlines, complicating members’ compliance efforts. Continued enforcement flexibility is therefore critical for ILMA members as they manage supply chain coordination, update safety data sheets and conduct downstream hazard classification.

ILMA members working toward HCS 2024 compliance can take advantage of ILMA’s training course, a free member benefit.