Hazard Communication in Virginia: VOSH and the 2024 HazCom Update
Short answer: Adopted, effective November 20, 2024 (corrections July 30, 2025 and August 28, 2026). Hazard communication in Virginia is enforced by VOSH under Virginia’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 Virginia
Virginia runs its own OSHA-approved State Plan. Workplace hazard communication is enforced by the Virginia Occupational Safety and Health (VOSH) Program, Virginia Department of Labor and Industry; standards are adopted by the Safety and Health Codes Board.
“The Virginia State Plan applies to private sector workplaces in the state”, except areas federal OSHA keeps, including maritime employment, contractors in U.S. Postal Service mail operations, worksites within federal military facilities and other federal enclaves, the Department of Energy’s Southeastern Power Administration Kerr–Philpott System, and aircraft cabin crew on aircraft in operation. It also applies to state and local government workers, but not federal government workers (osha.gov/stateplans/va).
The Virginia HazCom rule
16VAC25-90-1910.1200, part of Virginia’s Federal Identical General Industry Standards (Chapter 90).
Is the 2024 HazCom update in effect in Virginia?
“On September 23, 2024, the Safety and Health Codes Board adopted federal OSHA’s Final Rule for Hazard Communication Standard … with an effective date of November 20, 2024.” — Virginia Register, Vol. 41, Iss. 5
“Revise OSHA Hazard Communication Standard: Second Correction … This regulation became effective on 08/28/2026.” — Virginia Regulatory Town Hall, 16VAC25-90
We found no Virginia action adopting federal OSHA’s January 15, 2026 compliance-date extension (91 FR 1695) in the Virginia Register or on Town Hall, so we could not confirm which employer date VOSH enforces. The 2024 rule as first published set July 20, 2026 for substances; the extended federal date is November 20, 2026. Ask VOSH (contact VOSH); the cautious course is to treat the earlier date as already here.
Virginia-specific differences
Virginia adopts the federal text as a “federal identical” standard. osha.gov lists several VOSH-unique standards (for example tree trimming and reverse signal operation), none of them about hazard communication; we found no Virginia-only HazCom requirement.
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 VOSH. See Tier II reporting in Virginia.
Other State Plan states
See the 2024 HazCom update status in all State Plan states we cover.
Sources (checked October 10, 2026)
- Virginia Register, Vol. 41, Iss. 5
- Virginia Register: HCS Second Correction
- Virginia Regulatory Town Hall, 16VAC25-90
- 16VAC25-90-1910 (Virginia Administrative Code)
- osha.gov: Virginia State Plan
- eCFR: 29 CFR 1910.1200(j)
- Federal Register 91 FR 1695 (January 15, 2026)
Questions about how VOSH applies a rule to your workplace: contact VOSH.
Frequently asked questions
Has Virginia adopted the 2024 HazCom update?
Yes. Virginia's Safety and Health Codes Board adopted it effective November 20, 2024 (16VAC25-90-1910.1200), with corrections effective July 30, 2025 and August 28, 2026.
What is the HazCom deadline for Virginia employers?
We found no Virginia adoption of federal OSHA's January 15, 2026 date extension. The rule as first published set July 20, 2026 for employers (substances); the extended federal date is November 20, 2026. Ask VOSH which applies.
Who enforces HazCom in Virginia?
The VOSH Program of the Virginia Department of Labor and Industry, for private-sector and state and local government workplaces. Federal OSHA keeps some workplaces, such as federal military facilities.
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