Free tool
OSHA HazCom 2024 compliance date checker
OSHA updated its Hazard Communication Standard in May 2024 and extended the compliance dates in January 2026. Answer two questions to see which date applies to you and what has to be updated by then. Every date cites the regulation.
All HCS 2024 compliance dates
Compliance dates in 29 CFR 1910.1200(j), as extended by 91 FR 1695 (January 15, 2026). Checked against eCFR on 2026-10-20.
| Who | Comply by | Original date (2024 rule) | Citation |
|---|---|---|---|
| Manufacturers, importers and distributors evaluating substances | January 19, 2026 | 29 CFR 1910.1200(j)(2)(i) | |
| All employers, for substances | July 20, 2026 | 29 CFR 1910.1200(j)(2)(ii) | |
| Manufacturers, importers and distributors evaluating mixtures | July 19, 2027 | 29 CFR 1910.1200(j)(3)(i) | |
| All employers, for mixtures | January 19, 2028 | 29 CFR 1910.1200(j)(3)(ii) |
Transition rule. Between May 20, 2024 and the date that applies to you, you may comply with the updated standard, with the standard as it read on July 1, 2023 (the 2012 version), or with both. 29 CFR 1910.1200(j)(4); 91 FR 1695
The updated standard took effect July 19, 2024 (1910.1200(j)(1)). On January 15, 2026 OSHA extended all four compliance dates by four months (91 FR 1695), saying it needed time to publish guidance first. OSHA also published corrections on October 9, 2024 (89 FR 81829), January 8, 2026 (91 FR 562) and February 13, 2026 (91 FR 6760); those did not change the dates. States with OSHA-approved State Plans adopt changes through their own rulemaking, so their dates can differ (29 CFR 1953.5).
What has to be updated by each date
Manufacturers, importers and distributors evaluating substances: May 19, 2026
- Manufacturers and importers: classify each substance under the updated Appendices A and B, including hazards from a change in physical form and from reaction products of known or reasonably anticipated uses ((d)(1)).
- Distributors: pass on the updated labels and SDSs you receive ((b)(1), (g)(6)). Classification is the manufacturer's or importer's job ((d)(1)).
- Update shipped container labels to the 2024 Appendix C label elements ((f)(1)).
- Update safety data sheets to the 2024 Appendix D content, for example Section 2 (c) and Section 9 particle characteristics ((g), Appendix D).
- Apply the new label provisions where they fit your products: label updates and released-for-shipment containers ((f)(11)), small containers ((f)(12)), bulk shipments ((f)(5)(ii)).
- If you claim a concentration as a trade secret, use the prescribed ranges ((i)(1)(iv) to (vi)).
29 CFR 1910.1200(j)(2)(i)
All employers, for substances: November 20, 2026
- As necessary: update any alternative workplace labeling used under (f)(6), update your written hazard communication program ((h)(1)), and provide additional employee training ((h)(3)) for newly identified physical hazards, health hazards or other hazards.
29 CFR 1910.1200(j)(2)(ii)
Manufacturers, importers and distributors evaluating mixtures: November 19, 2027
- Manufacturers and importers: classify each mixture under the updated Appendices A and B, including hazards from a change in physical form and from reaction products of known or reasonably anticipated uses ((d)(1)).
- Distributors: pass on the updated labels and SDSs you receive ((b)(1), (g)(6)). Classification is the manufacturer's or importer's job ((d)(1)).
- Update shipped container labels to the 2024 Appendix C label elements ((f)(1)).
- Update safety data sheets to the 2024 Appendix D content ((g), Appendix D).
- Apply the new label provisions where they fit your products: (f)(11), (f)(12) and (f)(5)(ii).
- If you claim a concentration as a trade secret, use the prescribed ranges ((i)(1)(iv) to (vi)).
29 CFR 1910.1200(j)(3)(i)
All employers, for mixtures: May 19, 2028
- As necessary: update any alternative workplace labeling used under (f)(6), update your written hazard communication program ((h)(1)), and provide additional employee training ((h)(3)) for newly identified physical hazards, health hazards or other hazards.
29 CFR 1910.1200(j)(3)(ii)
Check label elements with the GHS H and P statement lookup and the GHS pictogram guide.
Related reading: HCS 2024 compliance checklist · OSHA HazCom standard: SDS and labels
What changed in 2024
The main changes in the May 20, 2024 final rule (89 FR 44144), as they read in the current regulation. This is a summary, not the full list.
- Aligned primarily with GHS Revision 7. The 2024 rule conforms the HCS to the UN GHS, primarily Revision 7. (89 FR 44144, summary)
- New and revised physical hazard classes. Adds desensitized explosives as a new hazard class (Appendix B.17). Splits flammable gases Category 1 into 1A and 1B, with pyrophoric gases and chemically unstable gases in 1A (B.2). Adds aerosol Category 3 for aerosols that do not meet the Category 1 or 2 criteria, and adds chemicals under pressure (B.3). (Appendix B.2, B.3, B.17; 89 FR 44144 preamble)
- Classification covers more of how a chemical is used. Classification must include hazards from a change in the chemical's physical form and from chemical reaction products of known or reasonably anticipated uses. Those reaction-product hazards go in SDS Section 2 (c). (1910.1200(d)(1); Appendix D, Table D.1)
- Released-for-shipment labeling. When new significant hazard information means a label must change within six months, containers already released for shipment do not have to be relabeled, as long as the updated label goes with each individual container in each shipment. (1910.1200(f)(11)(i))
- Small-container labels. Where the manufacturer, importer or distributor can demonstrate that pull-out labels, fold-back labels or tags are not feasible: containers of 100 ml or less need at least the product identifier, pictogram(s), signal word, manufacturer name and phone number, and a statement that the full label is on the immediate outer package. Containers of 3 ml or less can carry just the product identifier if any label would interfere with normal use. In both cases the immediate outer package must carry the full label and a statement that the small containers inside must be stored in that outer package when not in use. (1910.1200(f)(12)(i) to (iv))
- Bulk shipments and DOT pictograms. The label for a bulk shipment can be on the immediate container, sent with the shipping papers or bills of lading, or, if the receiver agrees, sent electronically so it is immediately available in printed form. Where a DOT pictogram appears on a shipped container, the HCS pictogram for the same hazard is not required on the label. Before 2024 the HCS pictogram could not appear next to a DOT pictogram for the same hazard; now it may. (1910.1200(f)(5)(ii) and (iii); definition of bulk shipment in (c); 89 FR 44144 preamble (former Appendix C.2.3.3))
- Trade secret concentration ranges. If you withhold a concentration as a trade secret, SDS Section 3 must give one of 13 prescribed ranges (for example 0.1% to 1%, 1% to 5%, 10% to 30%), using the narrowest range possible. (1910.1200(i)(1)(iv) to (vi); Appendix D, Section 3)
- SDS content updates. Section 9 now lists particle characteristics, and Section 2 adds the reaction-product hazards item described above. (Appendix D, Table D.1)
- HNOC pictogram option. The exclamation mark pictogram may be used for a hazard not otherwise classified (HNOC), but is not required, if the words "Hazard Not Otherwise Classified" or "HNOC" appear below it. (Appendix C, C.2.3.3)