Hazard Communication in Arizona: ADOSH and the 2024 HazCom Update

Short answer: Adopted, effective December 8, 2025. Hazard communication in Arizona is enforced by ADOSH under Arizona’s State Plan, and State Plans adopt federal OSHA’s 2024 update on their own timelines. Status, rule citation and dates checked October 10, 2026 against official sources linked below; not legal advice.

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Who enforces HazCom in Arizona

Arizona runs its own OSHA-approved State Plan. Workplace hazard communication is enforced by the Arizona Division of Occupational Safety and Health (ADOSH), part of the Industrial Commission of Arizona.

The Arizona State Plan “applies to all private sector workplaces in the state”, except areas federal OSHA keeps, including maritime employment, contractors on federal exclusive-jurisdiction establishments, U.S. Postal Service contractors, copper smelters, concrete and asphalt batch plants connected to a mine, Indian reservations, and aircraft cabin crew on aircraft in operation. It also applies to state and local government employers, but not federal government employers (osha.gov/stateplans/az).

The Arizona HazCom rule

Arizona Administrative Code R20-5-602, which incorporates 29 CFR 1910 by reference “with amendments as of January 13, 2025”.

Is the 2024 HazCom update in effect in Arizona?

“Each employer shall comply with the standards in Subparts B through Z … as published in 29 CFR 1910, with amendments as of January 13, 2025, incorporated by reference.” — A.A.C. R20-5-602 (Arizona Secretary of State, Supp. 26-3)

“Amended by final rulemaking at 32 A.A.R. 126 (January 2, 2026), with an immediate effective date of December 8, 2025 (Supp. 25-4).” — R20-5-602 historical note

R20-5-602 “does not include amendments or editions to 29 CFR 1910 published after January 13, 2025”, so as published it does not take in federal OSHA’s January 15, 2026 date extension (91 FR 1695); the text it incorporates sets July 20, 2026 for employers on substances. We could not confirm whether ADOSH has acted on the extension since. Ask ADOSH (contact ADOSH).

Arizona-specific differences

osha.gov says ADOSH “has adopted federal OSHA standards and incorporates them by reference”; its list of Arizona-unique standards does not include hazard communication, and we found no Arizona-only HazCom requirement. The Industrial Commission’s rulemaking page describes the change as incorporating “the Hazardous Communication standards for general industry” (ICA rulemaking activity).

The federal dates, for context

Federal OSHA’s updated standard was published May 20, 2024 (89 FR 44144) and took effect July 19, 2024. The compliance dates in 29 CFR 1910.1200(j) (eCFR, checked October 10, 2026) are:

Between May 20, 2024 and those dates, anyone covered may comply with the revised standard, the version in effect as of July 1, 2023, or both ((j)(4)). These dates already include the four-month extension OSHA published on January 15, 2026 (91 FR 1695); the 2024 rule as first published said January 19, 2026, July 20, 2026, July 19, 2027 and January 19, 2028. A State Plan that adopted the 2024 rule but not the extension, or that set its own dates, can have different deadlines, which is why the state section above matters.

What to do now (true in every state)

Every State Plan’s HazCom rule must be at least as effective as the federal one, so these basics apply whichever version your state enforces today:

• A written hazard communication program with a list of the hazardous chemicals on site, using the product identifier on each SDS. See what the written program must contain.
• A current SDS for every hazardous chemical, readily accessible to employees on every shift in their work areas. Your supplier writes the SDS and must send it with the first shipment; your job is to obtain, keep and give access to it. See SDS requirements for employers.
• Labels on shipped containers left intact, and workplace labels on containers you fill yourself. See secondary container labels.
• Training at initial assignment and whenever a new chemical hazard is introduced. See HazCom training requirements.
• The 2024 update: as revised SDSs arrive from suppliers, swap them in, and update workplace labels, the written program and training by the date that applies in your state (see above). If your state’s date is unclear, ask the agency and plan for the earliest possible date.

SDSentry keeps your library of supplier SDSs current and reachable from any phone, so swapping in revised sheets during the 2024 update is quick. SDSentry manages the SDSs your suppliers publish; it does not write them.

Tier II is a different law

EPCRA Tier II chemical inventory reporting comes from a separate federal law (the Emergency Planning and Community Right-to-Know Act, an EPA program) and is filed with state and local agencies, not with ADOSH. See Tier II reporting in Arizona.

Other State Plan states

See the 2024 HazCom update status in all State Plan states we cover.

Sources (checked October 10, 2026)

• A.A.C. Title 20, Chapter 5 (Supp. 26-3)
• Arizona Administrative Register, Vol. 32, Issue 1 (Notice of Final Rulemaking, p. 126)
• Industrial Commission of Arizona: rulemaking activity
• osha.gov: Arizona State Plan
• eCFR: 29 CFR 1910.1200(j)
• Federal Register 91 FR 1695 (January 15, 2026)

Questions about how ADOSH applies a rule to your workplace: contact ADOSH.

Educational information only, not legal or compliance advice. Requirements can vary by product, use and jurisdiction — verify at osha.gov/hazcom and 29 CFR 1910.1200, or consult a qualified professional.