The OSHA HazCom Deadline: November 20, 2026 for Substances, May 19, 2028 for Mixtures
Short answer: OSHA’s 2026 HazCom deadline is November 20, 2026: by then employers must, as necessary, update workplace labels, the written hazard communication program and employee training for hazards newly identified in substances under the 2024 update; the same updates for mixtures are due by May 19, 2028 (29 CFR 1910.1200(j)). The SDS dates (May 19, 2026 for substances, November 19, 2027 for mixtures) apply to chemical manufacturers, importers and distributors; an employer’s job is to keep the most recent sheet each supplier sends. The rule covers businesses of every size, and states with their own OSHA plan can set different dates. SDSentry ($24 per location per month, or $199 per year) keeps the SDS library, GHS labels, training records and written program for each location in one place. Here is the full picture.
The detail that decides it — What changes for employers, What changed, The compliance timeline and the checklist — is set out below.
Free, no signup: the SDS binder builder at sdsentry.0xpi.com/sds-binder.html turns a pasted list of the products you keep on site into one printable index of their current safety data sheets.
What changes for employers (HazCom 2024, checked 25 October 2026)
Paragraph (j) of 29 CFR 1910.1200 gives employers two dates: November 20, 2026 for substances and May 19, 2028 for mixtures. By each date, employers must, as necessary, make three updates for hazards newly identified under the 2024 rule:
- Labels: update any alternative workplace labels used under paragraph (f)(6), such as the in-house labels on secondary containers you fill yourself.
- Written program: update the hazard communication program required by paragraph (e): the list of hazardous chemicals and how labels, safety data sheets and training are handled.
- Training: provide additional training under paragraph (h)(3) on the newly identified physical, health or other hazards.
“As necessary” ties the work to what changed. Start from the revised safety data sheets and labels your suppliers send, and update the label, the program and the training for each product that now shows a hazard your workplace has not yet covered. Many everyday products, such as cleaners, paints and disinfectants, are mixtures, so their date is May 19, 2028. Until each date an employer may follow the 2012 version of the standard, the 2024 version, or both (paragraph (j)(4)). States that run their own OSHA plan adopt their own version and dates: see the 2024 update status by State Plan.
What changed
OSHA finalized the updated Hazard Communication Standard (29 CFR 1910.1200, often called "HCS 2024") in May 2024, effective July 19, 2024. It aligns U.S. rules with GHS Revision 7 and updates hazard classifications, label elements, and parts of the 16-section safety data sheet format. The changes are being phased in, with different dates for chemical manufacturers and for employers. For each change in the rule, see HazCom 2024 changes (GHS Rev 7).
The compliance timeline
In January 2026 OSHA extended the original deadlines by four months. The current dates:
| Who | For substances | For mixtures |
|---|---|---|
| Chemical manufacturers, importers & distributors | May 19, 2026 | November 19, 2027 |
| Employers (workplace labels, written program, training) | November 20, 2026 | May 19, 2028 |
Does this apply to my business?
Almost certainly yes. The Hazard Communication Standard covers any employer whose employees may be exposed to a hazardous chemical in the course of their work. A small animal shelter using disinfectants, a cleaning company with bleach and degreasers, an auto body shop with solvents and paints, a dental or veterinary practice with sterilants, a pool-service route with chlorine and acid — all are covered, the same as a large manufacturer. There is no small-business exemption from HazCom.
One exception to the date: if your state runs its own OSHA-approved State Plan (for example California, Washington, Oregon, Michigan, Virginia, North Carolina or Iowa), the state adopts its own version of the updated rule and its dates can differ. Check with your state program, or see the 2024 update status in all 22 private-sector State Plans.
Your checklist for November 20, 2026 (substances) and May 19, 2028 (mixtures)
- Update your chemical inventory and SDSs. Make sure you have the most recent safety data sheet your supplier has provided for every hazardous product on site, and file updated sheets as they arrive. OSHA's inspection directive (CPL 02-02-079) says HCS 2024 does not require employers to contact suppliers for new sheets for products they already have sheets for.
- Update workplace and secondary-container labels, as necessary, where a revised SDS shows a newly identified hazard (pictograms, signal word, hazard and precautionary statements).
- Update your written HazCom program (required by 29 CFR 1910.1200(e)) to reflect the current standard, your chemical list, and your procedures.
- Train employees on newly identified hazards (paragraph (h)(3)), as necessary, and document who was trained and when.
How SDSentry gets you ready
SDSentry is HazCom and SDS software built for small employers, and it covers exactly these four items in one place: a per-location SDS library with multi-source lookup (and your own uploads), GHS secondary-container labels, per-product training guides with e-signature records, and the written HazCom program — plus OSHA 300 recordkeeping and a no-login Shared SDS Binder so sheets are accessible during every shift. It is a flat $24 per location per month with unlimited users and a 7-day free trial, so a small business can keep these records current for each location.
Get ready for the deadline — start free
Frequently asked questions
When is the OSHA HazCom 2024 deadline for employers?
For substances, November 20, 2026: by then employers must, as necessary, update workplace labels, the written hazard communication program and employee training for newly identified hazards (29 CFR 1910.1200(j)(2)(ii)). OSHA extended this date by four months from July 20, 2026 (91 FR 1695, January 15, 2026). For mixtures, the employer date is May 19, 2028.
Does the November 20, 2026 date apply in states with their own OSHA plan?
Not automatically. About two dozen states and territories run an OSHA-approved State Plan instead of federal OSHA (for example California, Washington, Oregon, Michigan, Virginia, North Carolina and Iowa). A State Plan must adopt standards at least as effective as OSHA's, but it adopts its own version of the updated Hazard Communication rule, and its compliance dates can differ. If your state runs its own plan, check the date with your state program. State and local government employers are covered only where a State Plan covers public employees.
Does the HazCom 2024 update apply to small businesses?
Yes. OSHA's Hazard Communication Standard applies to any employer whose workers may be exposed to hazardous chemicals, regardless of company size. A small shelter, clinic, shop, or cleaning company with disinfectants, solvents, or other hazardous products is covered the same as a large facility.
What does an employer have to change by the deadline?
As necessary, three updates for newly identified hazards: alternative workplace and secondary-container labels (paragraph (f)(6)), the written HazCom program, and additional employee training (paragraph (h)(3)). Also keep the most recent SDS your supplier has provided for each product (HCS 2024 does not require you to request new sheets for products you already have sheets for).
What happens if a workplace is not compliant?
Hazard Communication is No. 2 on OSHA's preliminary FY2026 list of most frequently cited standards (osha.gov/top10citedstandards, checked Oct 2026). In our own dataset of federal HazCom citations, the written program and training account for most citations, followed by safety data sheets and labels. Verify your specific obligations at osha.gov and with a qualified safety professional.
A printable checklist for the HazCom 2024 update dates (November 20, 2026 for substances, May 19, 2028 for mixtures). We’ll email it to you — no account needed.