HazCom Updates: What ILMA Members Need to Know
Thank you to everyone who joined this week’s Q&A session on OSHA’s Hazard Communication Standard (HazCom) updates. Our panel of experts highlighted major changes that will significantly affect members both as mixture manufacturers and as employers, while also sharing tips for compliance readiness.
Watch the Recording
Key Takeaways
Compliance Deadlines Are Closer Than They Appear
- Updates to SDSs, labels, etc.: Jan. 19, 2026 (substances) & July 19, 2027 (mixtures)
- Updates to workplace labeling, written hazard communication programs and employee training: July 19, 2026 (substances) & Jan. 19, 2028 (mixtures)
- Canada transitions sooner — Dec. 14, 2025
Downstream Hazards Must Be Considered
Manufacturers must account for downstream hazards from “known or reasonably anticipated” uses. Good practices include reviewing available data, engaging with software providers, considering proactive supply chain communication, documenting due diligence, and monitoring OSHA guidance.
Importantly, there is no requirement to conduct intensive downstream investigations, and it is essential to remember that the standard is hazard-based, not risk-based.
Classification Changes Matter
- Health hazards: Incorporation of tiered data (in vitro/ex vivo) makes mixture classification more complex.
- Physical hazards: Aerosols now have their own classification and category system; new classes added for desensitized explosives and chemicals under pressure.
- SDSs: Trade secret concentration ranges are now prescribed and must be narrow.
Labeling Flexibility, But New Rules for Small Containers
- No need to relabel products already released for shipment if new hazards emerge.
- Small (≤100 mL) and very small (≤3 mL) containers may use reduced labeling, but outer packaging must include full details.
What You Can Do Now
- Begin gathering updated SDSs from suppliers and documenting outreach.
- Review your authoring software to ensure it will meet new requirements.
- Consider developing separate U.S. and Canadian SDSs to avoid compliance conflicts.
- Start employee training early — don’t wait until the deadlines.
- Enroll your team in ILMA’s upcoming Hazard Communication Training Series for step-by-step guidance. Keep an eye out for an email announcement coming soon!