HazCom 2024 Employer Compliance Deadline Approaches
Employers that use hazardous chemicals must update their workplace labels, written hazard communication programs and employee training by November 20, 2026. This deadline applies to substances under the Occupational Safety and Health Administration’s (OSHA) 2024 revision of the Hazard Communication Standard (HCS), 29 CFR 1910.1200. Employers have until May 19, 2028, to meet the requirements for mixtures.
Background
OSHA revised the Hazard Comunication Standard in May 2024 to align with Revision 7 of the Globally Harmonized System of Classification and Labelling of Chemicals (GHS), incorporating select elements of Revision 8. In January 2026, OSHA extended all compliance deadlines by four months to allow additional time for implementation guidance. The agency has since published a directive to guide compliance and enforcement.
Hazard communication is among OSHA’s most frequently cited standards. Members can access OSHA’s guidance through ILMA’s compliance resources, such as our HCS 2024 Compliance Support course and HCS 2024 Enforcement Policy Guide.
What ILMA Members Should Do Now
With the November 20 deadline approaching, members should review their chemical inventories to identify substances, as distinct from mixtures, subject to the deadline. Supply chain communication and documentation are also essential to compliance readiness.
Updated safety data sheets (SDSs) for substances should already be in circulation. If a shipment arrives without an updated SDS, promptly request one from the manufacturer or importer. Distributors that repackage products or market them under private brand names assume the manufacturer’s or importer’s legal obligations for SDS content.
For mixtures, members should begin planning updates to labels, written hazard communication programs and employee training well ahead of the May 2028 deadline rather than waiting until late 2027.
