Hazard Communication in New Mexico: NM OSHA and the 2024 HazCom Update
Short answer: Unconfirmed: no New Mexico adoption notice found. Hazard communication in New Mexico is enforced by NM OSHA under New Mexico’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 New Mexico
New Mexico runs its own OSHA-approved State Plan. Workplace hazard communication is enforced by the Occupational Health and Safety Bureau (OHSB, known as NM OSHA) of the New Mexico Environment Department.
“The New Mexico State Plan applies to private sector workplaces in the state”, except areas federal OSHA keeps, including maritime employment, U.S. Postal Service contractors, private establishments on military facilities and bases, employment within Indian reservations and tribal lands, the Western Area Power Administration site at Elephant Butte, and aircraft cabin crew on aircraft in operation. “The New Mexico State Plan also applies to state and local government employers”; it does not apply to federal government employers (osha.gov/stateplans/nm).
The New Mexico HazCom rule
11.5.2.9 NMAC, under which “the provisions of 29 CFR Part 1910 … are hereby incorporated” (with no “as of” date), with New Mexico amendments to 1910.1200 in 11.5.2.9(B)(5) NMAC.
Is the 2024 HazCom update in effect in New Mexico?
“A. General: Except as otherwise provided in Subsection B of this section, the provisions of 29 CFR Part 1910, Occupational Safety and Health Standards … are hereby incorporated into this section.” — 11.5.2.9 NMAC (NM State Records Center and Archives)
New Mexico-specific differences
New Mexico amends 1910.1200 in two places (11.5.2.9(B)(5) NMAC, with matching amendments for construction in 11.5.3.9 NMAC and agriculture in 11.5.4.9 NMAC) (11.5.2 NMAC):
- Employees who travel between sites: where work is carried out at more than one location, the safety data sheets “may be kept at a central location at the primary workplace facility”, provided employees “can immediately obtain the required information in an emergency” by telephone, two-way communication, computer or copies.
- Training credit for new hires: “a new employee shall be deemed to have been trained provided the employer can demonstrate the employee has received training regarding the same hazards within the past twelve months.”
The amendment text still says “material safety data sheets”, the pre-2012 term.
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 NM OSHA. See Tier II reporting in New Mexico.
Other State Plan states
See the 2024 HazCom update status in all State Plan states we cover.
Sources (checked October 10, 2026)
- 11.5.2 NMAC, General Industry
- 11.5.3 NMAC, Construction
- NM OSHA announcements
- osha.gov: New Mexico State Plan
- eCFR: 29 CFR 1910.1200(j)
- Federal Register 91 FR 1695 (January 15, 2026)
Questions about how NM OSHA applies a rule to your workplace: contact NM OSHA.
Frequently asked questions
Has New Mexico adopted the 2024 HazCom update?
We could not confirm it. 11.5.2.9 NMAC incorporates 29 CFR 1910 without a date, but on October 10, 2026 we found no New Mexico notice adopting the 2024 update or its compliance dates. Ask NM OSHA.
Can New Mexico employers keep SDSs at a central location?
For employees who travel between workplaces during a shift, yes: 11.5.2.9 NMAC lets the SDSs be kept centrally at the primary workplace if employees can get the information immediately in an emergency.
Who enforces HazCom in New Mexico?
The Occupational Health and Safety Bureau (NM OSHA) of the New Mexico Environment Department, for private-sector and state and local government workplaces, except areas federal OSHA keeps such as military bases and tribal lands.
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