Hazard Communication in Vermont: VOSHA and the 2024 HazCom Update

Short answer: Proposed November 2024; adoption not confirmed. Hazard communication in Vermont is enforced by VOSHA under Vermont’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 Vermont

Vermont runs its own OSHA-approved State Plan. Workplace hazard communication is enforced by the Vermont Occupational Safety and Health Administration (VOSHA), part of the Vermont Department of Labor.

“The Vermont State Plan applies to private sector workplaces in the state”, except areas federal OSHA keeps: offshore maritime employment (including offshore shipyard employment and longshoring), U.S. Postal Service contractors, and aircraft cabin crew on aircraft in operation. “The State Plan covers state and local government workers”; VOSHA does not cover federal government employers (osha.gov/stateplans/vt).

The Vermont HazCom rule

VOSHA adopts federal standards rule by rule, by reference (21 V.S.A. § 204(b)); its Hazard Communication rule in the Code of Vermont Rules is 24-050-037, which incorporates the 2012 GHS-aligned federal standard by reference.

Is the 2024 HazCom update in effect in Vermont?

“The Department of Labor is in the initial proposed rulemaking process of updating the Hazard Communication Standard. These rules have been adopted at the federal level, and Vermont is proposing to do the same.” — VOSHA Rules & Regulations page

The proposed text VOSHA posted uses the dates of the 2024 rule as first published (employers: July 20, 2026 for substances, January 19, 2028 for mixtures), not federal OSHA’s January 15, 2026 extension (91 FR 1695). If Vermont adopts it as proposed, those earlier dates would be in the text; the cautious course is to plan for July 20, 2026.

Vermont-specific differences

We found no Vermont employee chemical right-to-know law beyond the federal HazCom text; osha.gov lists VOSHA’s unique standards as Permissible Exposure Limits and Lineworker Safety (osha.gov/stateplans/vt). Vermont law also requires that “Each employer shall promptly notify any employee who has been or is being exposed to toxic materials or harmful physical agents in concentrations or at levels that exceed those prescribed by an applicable occupational safety and health standard” (21 V.S.A. § 228(2)) (21 V.S.A. chapter 3).

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 VOSHA. See Tier II reporting in Vermont.

Other State Plan states

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

Sources (checked October 10, 2026)

• VOSHA: Rules and Regulations
• VOSHA: proposed Hazard Communication text
• Vermont Secretary of State: rules search (rule 24P046)
• Code of Vermont Rules (24-050-037)
• 21 V.S.A. chapter 3
• osha.gov: Vermont State Plan
• eCFR: 29 CFR 1910.1200(j)
• Federal Register 91 FR 1695 (January 15, 2026)

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

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.