HCS 2024 is of extreme importance to ILMA members, in part because of the number of safety data sheets that may need to be updated along with container labels. The Association actively participated in the rulemaking process on HCS 2024, and ILMA is mentioned throughout the preamble to the final rule.

A key issue for ILMA members is the compliance deadlines:

Manufacturers, importers and distributors of “substances” must complete their evaluations of those substances by January 19, 2026. All employers (including downstream) must then, as necessary, update any alternative workplace labeling and hazard communication programs, and provide any additional employee training for newly identified physical, health or other covered hazards no later than July 20, 2026.

For “mixtures,” manufacturers, importers and distributors must be in compliance with all modified provisions of the HCS no later than July 19, 2027. Employers must then update alternative workplace labeling and hazard communication programs, and provide any additional employee training for newly identified physical, health or other covered hazards no later than January 19, 2028.

ILMA will update members with more detail soon.