Hazard Communication Standard Updates

Author: Kevin Chaplin

Compliance Deadline Extension Reminder

On January 8, 2026, the U.S. Occupational Safety and Health Administration (OSHA) issued a second corrections notice to further correct minor errors and make technical amendments that do not affect or change any existing requirements. Back in May 2024, OSHA issued a final rule updating the Hazard Communication Standard (HCS) (29 CFR §1910.1200) to align with Revision 7 (Rev. 7) of the standardized international system developed by the United Nations to define and communicate chemical hazards – The Globally Harmonized System (GHS) of Classification and Labeling of Chemicals. This is the first re-alignment (with a GHS Revision) since the original OSHA HCS was aligned with GHS in 2012. The final rule was published on May 20, 2024 and took effect on July 19, 2024.

On January 15, 2026, OSHA published an extension of compliance dates. The deadlines were extended for stakeholders as follows.

For Pure Substances:

• Manufacturers, Importers, and Distributors:
  • Old Deadline: January 19, 2026
  • New Deadline: May 19, 2026
  • Required Compliance Steps: Complete re-evaluations and updates of Safety Data Sheets (SDS) with new Rev. 7 hazard classes, publish updated SDS, and update container labels as needed.
• Downstream Employers:
  • Old Deadline: July 20, 2026
  • New Deadline: November 20, 2026
  • Required Compliance Steps: Update workplace labels, written Hazard Communication Program, and employee training to cover new chemical classifications and label information.

For Mixtures:

• Manufacturers, Importers, and Distributors:
  • Old Deadline: July 19, 2027
  • New Deadline: November 19, 2027
  • Required Compliance Steps: Classify compound mixtures and issue updated multi-ingredient SDS and labels. Align mixture-related labels and SDS with the updated standard and guidance.
• Downstream Employers:
  • Old Deadline: January 19, 2028
  • New Deadline: May 19, 2028
  • Required Compliance Steps: Finalize all employee retraining and alternative labeling for chemical mixtures.

The reason for the extension, according to the official OSHA Federal Register Notice, was to allow time to publish crucial guidance materials. Without these documents, businesses could face major bottlenecks trying to interpret complex new chemical classifications, small-container labeling exemptions, and modified SDS criteria. The extension was in response to significant feedback from industry stakeholders.

What Does This Mean To You And Action Items Moving Forward

The recommended approach is to tackle these changes systematically as the underlying text of the major OSHA update remains intact. To summarize the key impacts of the Rev. 7 alignment, most of the changes fall under one of the following themes as provided in current OSHA guidance:

1. Maintaining alignment with the GHS (primarily Rev. 7) and U.S. trading partners [including Health Canada’s Workplace Hazardous Materials Information System (WHMIS)]

• Paragraph (f)(12) – small packages. Updates include special labeling provisions for 3 milliliter (ml) and 100 ml containers similar to Health Canada’s WHMIS requirements.
• Paragraph (i) – trade secrets. Updates include mandatory use of prescribed concentration ranges when exact percentages or percentage ranges of materials are claimed as a trade secret. The prescribed concentration ranges align with those used by Health Canada’s WHMIS.
• Appendix A (health hazards) updates align primarily with revised health hazard definitions and general updates to hazard classes in GHS Rev. 7. Updates include, but are not limited to, the Skin corrosion/irritation and Serious eye damage/eye irritation chapters, with non-animal test methods from Rev. 8 added to skin corrosion/irritation to promote use of alternative methods.
• Appendix B (physical hazards) updates align primarily with Rev. 7 and include, but are not limited to, flammable gases (expanding hazard categories), desensitized explosives, and aerosols (including additional hazard category).
• Appendix C (label elements) updates align primarily with Rev. 7 and include new or updated hazards, updated guidance, and precautionary statements.
• Appendix D (SDS) updates align primarily with Rev. 7 and include revisions to SDS Sections 2, 3, 9, and 11.

2. Addressing issues identified during implementation of the 2012 update to the HCS

• Paragraph (d)(1) – hazard classification. The final rule clarifies which hazards must be evaluated and the hazard information required on the label versus the SDS.
• Paragraph (f)(11) – labels. The final rule adds flexibility for label updates on packages that have been released for shipment.
• Paragraph (f)(12) – labels. The final rule clarifies labeling requirements for small packages.

3. Improving alignment/coordination with other U.S. agencies

• Paragraph (f)(5) – bulk shipment. The final rule provides increased coordination with the U.S. Department of Transportation (DOT). There is a mandatory requirement for employers, handlers, and shippers to review hazard information (SDS) before an employee handles, mixes, or transports a hazardous chemical. This is called “first use” and has a different context between the two agencies. The OSHA standard refers to first use as the initial handling, application, or opening of a hazardous chemical in the workplace. This includes having an SDS on file, ensuring the container is properly labeled, and employee training is conducted to ensure safe handling. Under DOT’s Hazardous Materials Regulations the focus is on the safety of the shipment, ensuring the material is accurately classified (hazard class), packaged, and labeled before it leaves the facility.
• Paragraph (c) released for shipment definition – The final rule aligns with U.S. Environmental Protection Agency (U.S. EPA).

Unsure Where Your Organization Stands Regarding Compliance with the Revised Hazard Communication Standard?

Employers need to evaluate any SDS changes across all environmental, health, and safety programs including emissions calculations, Emergency Planning and Community Right-to-Know Act (EPCRA) reporting, and possibly effects on hazardous waste determinations.

ALL4 can help you evaluate your Hazard Communication Program and other safety programs to provide continuity throughout and allow your team to focus on what matters most, empowering your workforce, and running your business. For more information about how ALL4 can help support your safety programs, contact Kevin Chaplin at kchaplin@all4inc.com or (502) 254-0670.