Hazard Communication in Maryland: MOSH and the 2024 HazCom Update

Short answer: Not adopted as far as we could find; unconfirmed. Hazard communication in Maryland is enforced by MOSH under Maryland’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 Maryland

Maryland runs its own OSHA-approved State Plan. Workplace hazard communication is enforced by Maryland Occupational Safety and Health (MOSH), in the Division of Labor and Industry of the Maryland Department of Labor.

“The Maryland State Plan applies to all private sector workplaces in the state”, except areas federal OSHA keeps, including maritime employment, employment on military bases, U.S. Postal Service contractors, private employment on federal property where federal employees regularly work, federal contractor-operated sites and federal property under construction, and aircraft cabin crew on aircraft in operation. “The Maryland State Plan also applies to state and local government employers”; it does not apply to federal government employers (osha.gov/stateplans/md).

The Maryland HazCom rule

Md. Code, Labor and Employment §5-403(a), under which employers must comply with 29 CFR 1910.1200 “and, as adopted by the Commissioner, all subsequent amendments”; amendments are adopted by reference in COMAR 09.12.31.01, with Maryland’s Access to Information About Hazardous and Toxic Substances law in §§5-401 to 5-410 and COMAR 09.12.33.

Is the 2024 HazCom update in effect in Maryland?

“All amendments and revisions to 29 CFR §§1910 and 1926 … that appear in the Federal Register on March 26, 2012 (77 FR 17574—17896) are adopted by reference, as amended. Effective date: September 2, 2013” — COMAR 09.12.31.01 GG(4)

“… shall comply with all applicable provisions of the United States Department of Labor, Occupational Safety and Health Administration, “Hazard Communication Standard”, 29 C.F.R. 1910.1200 … and, as adopted by the Commissioner, all subsequent amendments.” — Md. Code, Lab. & Empl. §5-403(a)

Maryland-specific differences

Maryland Access to Information About Hazardous and Toxic Substances (Labor and Employment §§5-401 to 5-410, with COMAR 09.12.33) adds duties beyond the federal text (MOSH Right to Know):

• Chemical information list (§5-405): each employer must keep a list of every hazardous chemical in the workplace, with its chemical and common names and each work area where it is found, in alphabetical order by common name. “Within 30 days after a hazardous chemical is introduced into the workplace of an employer, the employer shall add the hazardous chemical” to the list; “Every 2 years, an employer shall revise the chemical information list”; and each list must be kept for at least 40 years (§5-405).
• Employee access (§5-407): access to the list and SDSs within 1 working day after a request, and a copy within 5 days; if the employer does not comply, the employee “may refuse to work with the hazardous chemical” in question (§5-407).
• Wood products and trade secrets (§5-403): “The exclusion for wood and wood products set forth in 29 C.F.R. 1910.1200(b)(6)(iii) does not apply in Maryland”, and a party claiming a trade secret has the burden of proving it.
• Contractors and fire departments (§§5-408, 5-409): contractors exchange chemical information lists before work starts, and employers must give fire department officials the lists and SDSs on request.
• List format (COMAR 09.12.33.02): the first page shows the employer’s name and address, a contact person and the date of preparation or revision, and each added chemical is dated (COMAR 09.12.33.02).

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 MOSH. See Tier II reporting in Maryland.

Other State Plan states

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

Sources (checked October 10, 2026)

• COMAR 09.12.31.01
• Md. Code, Lab. & Empl. 5-403
• Md. Code, Lab. & Empl. 5-405
• Md. Code, Lab. & Empl. 5-407
• COMAR 09.12.33.02
• MOSH Standard Notices
• osha.gov: Maryland State Plan
• eCFR: 29 CFR 1910.1200(j)
• Federal Register 91 FR 1695 (January 15, 2026)

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

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.