Hazard Communication in Minnesota: MNOSHA and the 2024 HazCom Update

Short answer: Adopted November 4, 2024 (corrections October 13, 2025). Hazard communication in Minnesota is enforced by MNOSHA under Minnesota’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 Minnesota

Minnesota runs its own OSHA-approved State Plan. Workplace hazard communication is enforced by Minnesota OSHA (MNOSHA), administered by the Minnesota Department of Labor and Industry.

The Minnesota State Plan “applies to private-sector workplaces in the state”, except areas federal OSHA keeps, including offshore maritime employment, establishments owned or operated by a tribe or enrolled member within a reservation or on trust lands, U.S. Postal Service contractors, land under exclusive federal jurisdiction next to the former Twin Cities Army Ammunition Plant, and aircraft cabin crew on aircraft in operation. “The Minnesota State Plan covers State and local government employers and employees”; federal OSHA covers federal government employers (osha.gov/stateplans/mn).

The Minnesota HazCom rule

Minn. R. 5205.0010, which adopts 29 CFR 1910 by reference (subp. 2 lists the May 20, 2024 and October 9, 2024 Hazard Communication rules), plus Minnesota’s Employee Right-to-Know rules, Minn. R. chapter 5206.

Is the 2024 HazCom update in effect in Minnesota?

“On Nov. 4, 2024, and Oct. 13, 2025, Minnesota OSHA adopted the final rule and the final rule correction and technical amendments described above.” — Minnesota DLI, MNOSHA rulemaking

“UU. Federal Register, Volume 89, No. 98, pages 44144-44461, dated May 20, 2024: “Hazard Communication Standard.”” — Minn. R. 5205.0010, subp. 2

The 2026 federal date extension: we could not confirm from an official Minnesota source on October 10, 2026 whether MNOSHA has also adopted federal OSHA’s January 15, 2026 four-month extension of the compliance dates (91 FR 1695). The 2024 rule as first published set July 20, 2026 for employers to update labels, the written program and training for substances, and January 19, 2028 for mixtures; with the extension, the federal dates are November 20, 2026 and May 19, 2028. Ask MNOSHA which date it enforces (contact MNOSHA). The cautious course is to treat the earlier date as already here.

Minnesota-specific differences

Minnesota Employee Right-to-Know (ERTK) applies alongside HazCom and goes further on training and records (Minn. R. 5206.0700):

• A written Employee Right-to-Know program covering hazardous substances, harmful physical agents and infectious agents (Minn. R. 5206.0700, subp. 1(B)).
• Training “before initial assignment to a workplace where the employee may be routinely exposed” (subp. 1(G)(1)), and “Training updates must be repeated at intervals of not greater than one year” (subp. 1(G)(4)). Federal HazCom has no annual refresher.
• Training records kept for three years, with dates, the trainer’s name and qualifications, trainees’ names and job titles, and a summary of content (subp. 1(D)).

MNOSHA’s directive CPL 2-2.38B says: “Requirements for annual training and recordkeeping, though not part of 1910.1200, will continue to be enforced under ERTK” (CPL 2-2.38B).

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 MNOSHA. See Tier II reporting in Minnesota.

Other State Plan states

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

Sources (checked October 10, 2026)

• Minnesota DLI: MNOSHA rulemaking
• Minn. R. 5205.0010
• Minn. R. 5206.0700
• MNOSHA CPL 2-2.38B
• osha.gov: Minnesota State Plan
• eCFR: 29 CFR 1910.1200(j)
• Federal Register 91 FR 1695 (January 15, 2026)

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

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.