Hazard Communication in North Carolina: NC OSH and the 2024 HazCom Update
Short answer: Adopted, effective January 1, 2025; federal date extension adopted effective June 1, 2026. Hazard communication in North Carolina is enforced by NC OSH under North Carolina’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 North Carolina
North Carolina runs its own OSHA-approved State Plan. Workplace hazard communication is enforced by the Occupational Safety and Health Division of the North Carolina Department of Labor (NC OSH).
“The NC OSH Division covers private sector workplaces in the state”, except areas federal OSHA keeps, including maritime employment, contractors in U.S. Postal Service mail operations, employment on Indian reservations, contractors on federal establishments where the land has been ceded to the federal government, railroad employment not regulated by another federal agency, military bases and the American National Red Cross. The State Plan does not cover federal government employers (osha.gov/stateplans/nc).
The North Carolina HazCom rule
13 NCAC 07F .0101, which incorporates 29 CFR Part 1910 by reference (published on or before February 13, 2026), except as modified in 13 NCAC 07F .0103 (which does not modify 1910.1200).
Is the 2024 HazCom update in effect in North Carolina?
“The N.C. Commissioner of Labor adopted this final rule verbatim with an effective date of January 1, 2025.” — NCDOL CFR Revision 101D
“Effective June 1, 2026, North Carolina adopted the federal OSHA updates made to the compliance dates in the Hazard Communication Standard, 29 CFR 1910.1200. The compliance dates listed in the standard were extended by four months.” — NCDOL Standards Information and Activity
North Carolina-specific differences
North Carolina Hazardous Chemicals Right to Know Act (G.S. Chapter 95, Article 18) is a separate state law (G.S. 95, Article 18). Among other things, an employer that stores a hazardous chemical in quantities of 55 gallons or 500 pounds, whichever is greater, must keep a Hazardous Substance List, updated at least annually (§ 95-191), and give the fire chief with jurisdiction the list and the names and phone numbers of knowledgeable contacts (§ 95-194).
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 NC OSH. See Tier II reporting in North Carolina.
Other State Plan states
See the 2024 HazCom update status in all State Plan states we cover.
Sources (checked October 10, 2026)
- NCDOL CFR Revision 101D
- NCDOL Standards Information and Activity
- 13 NCAC 07F .0101 (NC OAH)
- osha.gov: North Carolina State Plan
- eCFR: 29 CFR 1910.1200(j)
- Federal Register 91 FR 1695 (January 15, 2026)
Questions about how NC OSH applies a rule to your workplace: contact NC OSH.
Frequently asked questions
Has North Carolina adopted the 2024 HazCom update?
Yes. NCDOL adopted the May 20, 2024 rule verbatim effective January 1, 2025, and adopted federal OSHA's four-month compliance date extension effective June 1, 2026.
What is the HazCom deadline for North Carolina employers?
North Carolina adopted the federal date extension, so employers must update labels, the written program and training for substances by November 20, 2026 and for mixtures by May 19, 2028.
Does North Carolina have its own chemical right-to-know law?
Yes. The Hazardous Chemicals Right to Know Act (G.S. 95, Article 18) requires a Hazardous Substance List for chemicals stored at 55 gallons or 500 pounds or more and information for the local fire chief.
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