Hazard Communication in Michigan: MIOSHA and the 2024 HazCom Update
Short answer: Adopted, effective August 12, 2025. Hazard communication in Michigan is enforced by MIOSHA under Michigan’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 Michigan
Michigan runs its own OSHA-approved State Plan. Workplace hazard communication is enforced by the Michigan Occupational Safety and Health Administration (MIOSHA), part of the Michigan Department of Labor and Economic Opportunity.
“The Michigan State Plan applies to private-sector workplaces in the state”, except areas federal OSHA keeps, including maritime employment (but not marine construction), contractors in U.S. Postal Service mail operations, enrolled tribal members’ businesses within reservation boundaries, 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/mi).
The Michigan HazCom rule
MIOSHA Hazard Communication standards Part 92 (general industry, R 408.19201–408.19204), Part 42 (construction, R 408.44201–408.44204) and Part 430 (occupational health, R 325.77001–325.77004), which adopt 29 CFR 1910.1200 by reference, together with sections 14a to 14l of the Michigan Occupational Safety and Health Act.
Is the 2024 HazCom update in effect in Michigan?
“(as amended August 5, 2025 – effective August 12, 2025)” — MIOSHA combined Hazard Communication standard, Parts 42, 92, 430
“29 CFR 1910.1200 ‘Hazard Communication,’ July 19, 2024.” — R 408.19202 (adopted by reference)
The federal text MIOSHA reprints in its combined standard (MIOSHA-STD-1600, dated 02/26) shows the dates of the 2024 rule as first published: July 20, 2026 for employers on substances and January 19, 2028 on mixtures. We could not confirm from a Michigan source whether MIOSHA has adopted federal OSHA’s January 15, 2026 extension (91 FR 1695). Ask MIOSHA (contact MIOSHA); the cautious course is to treat July 20, 2026 as the date.
Michigan-specific differences
Michigan’s statute adds duties beyond the federal text (all reprinted in MIOSHA’s combined HazCom standard):
- New or revised SDS notice: “Not later than 5 working days after receipt of a new or revised safety data sheet, the employer shall post for a period of 10 working days a notice of the existence of the new or revised sheet and directions for locating” it (MCL 408.1014k(2)). This matters during the 2024 update, as revised SDSs arrive.
- Organised SDSs: the employer shall organise SDSs “in a systematic and consistent manner and shall train employees in locating particular safety data sheets” (MCL 408.1014k(1)).
- Signs: employers must post signs telling employees where the SDSs are and who to get them from, that employees may not be discharged or discriminated against for exercising these rights, and that they can get an SDS copy from the department (MCL 408.1014j). MIOSHA publishes the posters (#2105 and #2106).
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:
| Who | What | Federal date |
|---|---|---|
| Chemical manufacturers, importers and distributors | Substances: comply with all modified provisions ((j)(2)(i)) | May 19, 2026 |
| All employers | Substances: as necessary, update alternative workplace labeling under (f)(6), the hazard communication program, and training for newly identified hazards ((j)(2)(ii)) | November 20, 2026 |
| Chemical manufacturers, importers and distributors | Mixtures: comply with all modified provisions ((j)(3)(i)) | November 19, 2027 |
| All employers | Mixtures: the same employer updates ((j)(3)(ii)) | May 19, 2028 |
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 MIOSHA. See Tier II reporting in Michigan.
Other State Plan states
See the 2024 HazCom update status in all State Plan states we cover.
Sources (checked October 10, 2026)
- MIOSHA-STD-1600, Hazard Communication (Parts 42, 92, 430)
- osha.gov: Michigan State Plan
- eCFR: 29 CFR 1910.1200(j)
- Federal Register 91 FR 1695 (January 15, 2026)
Questions about how MIOSHA applies a rule to your workplace: contact MIOSHA.
Frequently asked questions
Has Michigan adopted the 2024 HazCom update?
Yes. MIOSHA amended its Hazard Communication Parts 42, 92 and 430 effective August 12, 2025, adopting 29 CFR 1910.1200 as of July 19, 2024 by reference.
What does Michigan require when a new SDS arrives?
Within 5 working days of receiving a new or revised SDS, the employer must post, for 10 working days, a notice that it exists and where to find it (MCL 408.1014k(2)).
What is the HazCom deadline for Michigan employers?
MIOSHA's published text shows July 20, 2026 for employers (substances) and January 19, 2028 (mixtures). We could not confirm whether Michigan adopted the federal extension to November 20, 2026; ask MIOSHA.
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