HazCom 2026 Deadline Checklist
Use this before November 20, 2026. OSHA's updated Hazard Communication Standard (HCS 2024, aligned with GHS Revision 7) requires every employer to bring its labels, written program, and training up to the new format by then. Here is everything to check off — print it, work through it, and you'll be ready. (Full background is in our OSHA HazCom 2026 deadline guide.)
1. Chemical inventory & safety data sheets
- List every hazardous chemical on site (do each location separately).
- Confirm a current SDS, in the updated 16-section GHS format, for every product.
- Replace or re-pull any sheet that's outdated or still in the old MSDS format.
2. Labels
- Check that shipped containers carry a compliant GHS label (pictograms, signal word, hazard & precautionary statements).
- Label every secondary container — spray bottles, decanted product, refill jugs — with at least the product name and the hazard information.
3. Written HazCom program
- Have a written Hazard Communication program (required by 29 CFR 1910.1200(e)).
- Update it to reflect the current standard, your chemical list, and how you label, store, and train.
4. Employee training
- Train every employee on the revised GHS label elements and the SDS format.
- Train new hires before they work with hazardous chemicals, and whenever a new hazard is introduced.
- Document who was trained, on what, and when — and keep the records.
5. Access
- Make sure SDSs are readily accessible to employees on every shift.
- Have a backup for an internet or power outage (printed copies or offline access).
6. Hit the deadline
- Everything above complete for substances by November 20, 2026.
- Plan for the parallel mixtures deadline of May 19, 2028.
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