OSHA’s updated Hazard Communication Standard is entering an important phase of implementation, with a major employer deadline approaching November 20, 2026. Employers should use the coming months to review their written Hazard Communication program, Safety Data Sheets (SDSs), workplace labels, and employee training to determine what updates may be necessary.
Hazard Communication is one of the most familiar OSHA requirements. Most employers already have a written program, maintain SDSs and secondary container labels, and provide employee training. However, because this framework has existed for decades, it can be easy to assume that an established HazCom program requires little attention.
What Changed?
OSHA updated the Hazard Communication Standard in May 2024 to align with the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS).
The fundamental responsibility has not changed: employees must still receive information about hazardous chemicals through labels, SDSs, written programs, and training. However, the revised standard changes certain requirements for how hazards are classified and how that information is communicated.
Many of these changes initially fell on chemical manufacturers, importers, and distributors. Those organizations were required to comply with the revised provisions by May 19, 2026. They updated their chemical information by revising SDSs and labels and began packaging their chemicals with the new information. Employers must now take the updated chemical information and determine whether changes are necessary in their workplaces.
What the November 20, 2026 Deadline Does—and Does Not—Require
- Employees do not automatically have to complete a new Hazard Communication course.
- Employers must update their labels and their written Hazard Communication program as needed if their chemicals, SDSs, or labels have changed.
- Employers must provide employee training for newly identified hazards.
If an updated SDS identifies a new hazard, an employer may need to revise workplace information and provide employees with additional training based on the chemicals and hazards present in the workplace.
Start With Your Chemical Inventory and SDSs
Employers do not need to rewrite their entire Hazard Communication program. A good starting point is the chemical inventory and corresponding SDS library.
- First: Determine whether manufacturers or suppliers have issued updated SDSs and whether revised classifications or hazard information affect how those chemicals are used or communicated in your workplace.
- Second: Review workplace labeling, particularly secondary containers. If the underlying hazard information has changed, the information employees rely upon must be updated.
- Third: Compare any changes with your written Hazard Communication program and update the program as necessary to reflect current terminology, chemical information, and workplace practices.
Training: Address What Changed
Employees still need to understand the fundamentals of Hazard Communication, including labels, pictograms, SDSs, protective measures, and how to obtain hazard information.
When newly identified hazards require additional training, that training should focus on the specific change. Employees should understand the new hazard, how exposure could occur, appropriate protective measures, and where additional information can be found.
The compliance deadlines are not the only recent development—OSHA also updated its inspection procedures. On May 19, 2026, OSHA issued CPL 02-02-079, Inspection Procedures for the Hazard Communication Standard (HCS 2024), providing compliance personnel with inspection and enforcement procedures for the revised standard.
This makes the approaching November compliance deadline an even more appropriate time to identify gaps before an OSHA inspection or incident does it for you.
Chemical inventories, SDS access, workplace labeling, written procedures, and employee knowledge should collectively demonstrate how hazardous chemicals are managed within the organization.
The transition does not end in November 2026. OSHA established later compliance dates for mixtures, meaning employers may continue receiving updated SDSs and labels and should continue reviewing new chemical information as it enters the workplace.
For most employers, preparing for these changes does not require creating an entirely new safety program. It means reviewing what is already in place and asking some practical questions:
- Is our chemical inventory accurate?
- Are current SDSs readily accessible?
- Have revised SDSs identified any new hazards?
- Do workplace and secondary-container labels remain accurate?
- Does our written program reflect current practices?
- Do employees need additional training because hazard information has changed?
Hazard Communication has always been based on a straightforward principle: workers have the right to understand the chemical hazards they face and how to protect themselves. The Hazard Communication updates do not change that principle, but they do update portions of the system used to communicate that information.
The November 20 deadline is an opportunity to ensure the Hazard Communication program employees rely on is as current as the chemicals they work with—and that labels, SDSs, written procedures, and training all communicate the same information.
Have questions about how the Hazard Communication changes may affect your organization? Contact TMC for assistance reviewing your current program and preparing for the November 2026 deadline.