Is the 2024 HazCom Update in Effect in My State? State Plan Status

Short answer: it depends on the state. Of the 22 State Plans that cover private employers, 15 have adopted the 2024 Hazard Communication update, Tennessee and Vermont have only proposed it, we found no adoption in California, Hawaii, Maryland or Puerto Rico, and we could not confirm New Mexico’s status. Washington and Oregon set their own deadlines; North Carolina, Alaska, Utah and Wyoming are confirmed on the federal November 20, 2026 employer date. Status checked October 10, 2026 against official sources; not legal advice.

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Status by state

Each row links to a page with the agency, the rule, the official source and a quote. Everything was checked October 10, 2026.

“Not adopted as far as we found” means the state’s official rule text and rulemaking records we checked show no adoption, which cannot rule out an action we did not find; ask the agency. “Not confirmed” means the state adopted the 2024 rule, whose text as first published set July 20, 2026, and we could not confirm from an official state source whether it also adopted federal OSHA’s January 15, 2026 extension to November 20, 2026 (91 FR 1695). Ask the agency; the cautious course is to treat the earlier date as already here.

Why the dates differ by state

osha.gov lists 29 OSHA-approved State Plans, 22 of which cover private-sector employers. State Plans must be at least as effective as OSHA, but each adopts new federal standards through its own process: some by reference within months, some with their own effective dates, and some, like Washington and Oregon, with their own compliance deadlines. So the federal November 20, 2026 employer date is not automatically the date in a State Plan state.

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.

State Plans that cover only public employers

osha.gov lists 22 State Plans covering both private-sector and state and local government workers, all in the table above, and 7 covering only state and local government workers: Connecticut, Illinois, Maine, Massachusetts, New Jersey, New York and the U.S. Virgin Islands (osha.gov/stateplans, checked October 10, 2026). In those 7, private employers are under federal OSHA, so the federal dates below apply to them. State and local government employers there should check the 2024 HazCom update status with their State Plan agency, which osha.gov links from its State Plans page.

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, whichever date applies in your state. SDSentry manages the SDSs your suppliers publish; it does not write them.

Tier II is a different law

EPCRA Tier II chemical inventory reporting is an EPA program, not OSHA’s, and has its own state agencies and thresholds. See Tier II thresholds by state.

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.