Hazard Communication in California: Cal/OSHA and the 2024 HazCom Update

Short answer: Not adopted as far as we could find; unconfirmed. Hazard communication in California is enforced by Cal/OSHA under California’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 California

California runs its own OSHA-approved State Plan. Workplace hazard communication is enforced by the Division of Occupational Safety and Health (Cal/OSHA) in the Department of Industrial Relations; standards are set by the Occupational Safety and Health Standards Board.

“The California State Plan covers all private-sector places of employment within the state”, except areas federal OSHA keeps, including maritime employment on navigable waters (other than marine construction on bridges and on shore), tribal lands, federal enclaves under exclusive federal jurisdiction, U.S. Postal Service contractors 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/ca).

The California HazCom rule

California Code of Regulations, Title 8, Section 5194, Hazard Communication (General Industry Safety Orders, Group 16, Article 109).

Is the 2024 HazCom update in effect in California?

“(j) Effective dates. (1) Employers shall train employees regarding the new label elements and safety data sheets format by December 1, 2013.” — 8 CCR 5194 (DIR)

“This database is current through 9/28/18” — 8 CCR 5194 page footer (DIR)

California-specific differences

8 CCR 5194 has California-specific provisions (8 CCR 5194):

• Proposition 65 interface (5194(b)(6)): an employer that is a “person in the course of doing business” under Proposition 65 must comply with it as 5194 sets out; for hazardous substances that also need a Prop 65 warning, complying with 5194 subsections (d) through (k) “shall be deemed compliance with the Act”. Employers with fewer than ten employees, government entities and public water systems are not subject to the Act.
• California’s list: substances on the Director’s hazardous substances list (8 CCR 339) must be treated as hazardous chemicals (5194(d)(3)(A)).
• SDS copies to the state: “The preparer of a safety data sheet shall provide the Director with a copy of the safety data sheet” (5194(g)(13)). This is a duty on the SDS preparer (the supplier), not on an employer that only uses the product.

Proposition 65 itself is a separate state law administered by OEHHA: it “requires businesses to provide warnings to Californians about significant exposures to chemicals that cause cancer, birth defects or other reproductive harm” (OEHHA, About Proposition 65).

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 Cal/OSHA. See Tier II reporting in California.

Other State Plan states

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

Sources (checked October 10, 2026)

• 8 CCR 5194 (DIR)
• Standards Board: Proposed Regulations
• Standards Board: Approved Regulations
• OEHHA: About Proposition 65
• osha.gov: California State Plan
• eCFR: 29 CFR 1910.1200(j)
• Federal Register 91 FR 1695 (January 15, 2026)

Questions about how Cal/OSHA applies a rule to your workplace: contact Cal/OSHA.

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.