Hazard Communication in Tennessee: TOSHA and the 2024 HazCom Update

Short answer: Proposed, not yet adopted (rules in effect adopt 29 CFR 1910 as of January 1, 2022). Hazard communication in Tennessee is enforced by TOSHA under Tennessee’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 Tennessee

Tennessee runs its own OSHA-approved State Plan. Workplace hazard communication is enforced by Tennessee OSHA (TOSHA), part of the Tennessee Department of Labor and Workforce Development.

The Tennessee 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, railroad employment not regulated by another federal agency, Tennessee Valley Authority facilities and military bases, and aircraft cabin crew on aircraft in operation. TOSHA “covers state and local government workers but does not cover federal government employers including USPS” (osha.gov/stateplans/tn).

The Tennessee HazCom rule

Tenn. Comp. R. & Regs. 0800-01-01-.06, which adopts 29 CFR Part 1910 by reference, plus Tennessee’s own Hazardous Chemical Right to Know rules, Chapter 0800-01-09.

Is the 2024 HazCom update in effect in Tennessee?

“The Commissioner … adopts the federal occupational safety and health standards codified in Title 29, Code of Federal Regulations, Part 1910, as of January 1, 2022” — Tenn. Comp. R. & Regs. 0800-01-01-.06 (Secretary of State)

“… Part 1910, as of May 1, 2025” — Notice of Rulemaking Hearing, filed 2/4/2026 (proposed text)

Because the proposal stops at May 1, 2025, it would not by itself pick up federal OSHA’s January 15, 2026 date extension (91 FR 1695). Until a final rule takes effect, ask TOSHA which version and dates it enforces (contact TOSHA).

Tennessee-specific differences

Tennessee Hazardous Chemical Right to Know rules (Chapter 0800-01-09) apply alongside HazCom and add duties, including (Chapter 0800-01-09):

• Refresher training: “Refresher training shall be provided at least annually thereafter” (0800-01-09-.07).
• A Workplace Chemical List, to be filed with the Commissioner within 96 hours of a request (0800-01-09-.11), with a copy to the fire chief with jurisdiction (0800-01-09-.10).
• Signs in work areas where non-containerized hazardous chemicals are generated, such as welding fumes (0800-01-09-.06(2)).
• Records: training records kept for the period of employment plus 5 years, and Workplace Chemical Lists for 30 years (0800-01-09-.12).

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 TOSHA. See Tier II reporting in Tennessee.

Other State Plan states

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

Sources (checked October 10, 2026)

• Tenn. Comp. R. & Regs. 0800-01-01
• Notice of Rulemaking Hearing 02-05-26
• TN Secretary of State: pending rules
• Chapter 0800-01-09, Hazardous Chemical Right to Know
• osha.gov: Tennessee State Plan
• eCFR: 29 CFR 1910.1200(j)
• Federal Register 91 FR 1695 (January 15, 2026)

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

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.