OSHA’s November 2026 HazCom Deadline: What Employers Should Be Doing Now
The Occupational Safety and Health Administration (OSHA) updated its Hazard Communication Standard (HazCom) in 2024 to improve the information provided to employees about hazardous chemicals. Following an extension of the compliance dates earlier this year, employers now have until November 20, 2026, to implement the necessary updates.
For facilities that use hazardous chemicals, this deadline presents an opportunity to review safety data sheets (SDSs), workplace labels, written programs, and employee training to determine whether changes are needed.
What Changed?
The revised standard primarily aligns with Revision 7 of the United Nations’ Globally Harmonized System of Classification and Labelling of Chemicals (GHS). Changes include revisions to certain hazard classifications, requirements for small-container labeling, and information provided in SDSs.
For example, OSHA revised classifications for flammable gases and aerosols and added a hazard class for desensitized explosives. The standard also includes updated precautionary statements and changes to requirements for certain information withheld as trade secrets.
These revisions may result in updated hazard information from chemical suppliers, even if the chemical itself has not changed.
Who Does the Deadline Apply To?
Under 29 CFR 1910.1200(j)(2)(ii), employers must, as necessary, update workplace labeling, their hazard communication program, and employee training for newly identified hazards associated with substances by November 20, 2026.
The distinction between substances and mixtures is important. A substance is generally an individual chemical element or compound, while a mixture contains two or more substances. Manufacturers, importers, and distributors evaluating substances had a compliance deadline of May 19, 2026. For mixtures, their deadline is November 19, 2027, followed by May 19, 2028, for employers’ necessary updates.
Employers should review supplier information to determine which timeline applies to the chemicals at their facility.
| Chemical type | Manufacturers, importers, distributors | Employers using the chemicals |
|---|---|---|
| Substances | By May 19, 2026: comply with the revised requirements, including SDS and label updates | By November 20, 2026: make updates to workplace labels, written programs, and training |
| Mixtures | By November 19, 2027: comply with the revised requirements, including SDS and label updates | By May 19, 2028: make updates to workplace labels, written programs, and training |
What Should be Reviewed?
Start by confirming your chemical inventory and obtaining updated SDSs from suppliers. Review the information to identify any changes that may affect your facility’s labeling, procedures, protective equipment, or training.
The standard requires updates as necessary, so the extent of the work will depend on the substances used and the changes identified. However, receiving an updated SDS is only part of the process. Employers must evaluate how the information affects employees’ work and communicate the necessary changes.
Employers must always provide employees with access to SDSs, appropriate labeling, and HazCom training.
How Walden Can Help
If you need assistance evaluating your facility’s compliance with OSHA standards, Walden can help! Contact us at 860-846-4069 to speak with an Environmental Health and Safety (EHS) specialist today.