The Hazard Communication Deadline Is Here — What Employers Should Double-Check Now

In May 2024, the Occupational Safety and Health Administration (OSHA) published a final rule updating the Hazard Communication Standard (HCS) to align primarily with the 7th revision of the United Nations’ Globally Harmonized System (GHS). The rule became effective in July 2024, beginning a phased compliance timeline for manufacturers, importers, distributors, and employers who use hazardous chemicals.

At the time, we outlined what was changing and what employers should begin preparing for.

Now, the hazard communication deadline phase has arrived.

The transition period is shrinking, and employers should confirm their programs are fully aligned with the revised standard.

Why the Hazard Communication Deadline Matters in 2026

When OSHA finalized the HCS update in 2024, the agency built in a phased implementation period. That allowed manufacturers, importers, distributors, and employers time to transition from the 2012 version of the standard to the updated requirements.

But as 2026 milestone dates arrive, the hazard communication deadline is no longer something to prepare for — it’s something to verify.

Inspectors will increasingly expect compliance with the revised classifications, labeling provisions, and Safety Data Sheet (SDS) updates.

new hazard communication deadline chart
New Hazard Communication Deadlines

What Employers Should Double-Check Before the Hazard Communication Deadline Passes

Even if you reviewed the rule in 2024, now is the time to confirm full implementation:

1. Updated Labels

  • Are manufacturer labels reflecting GHS Revision 7 classifications?
  • Are small container provisions (≤100 ml and ≤3 ml) being followed properly?
  • Do in-house workplace labels match updated hazard classifications?

2. Safety Data Sheets (SDSs)

  • Have outdated SDSs been replaced with updated versions?
  • Are trade secret concentration ranges compliant with prescribed ranges?
  • Are SDSs readily accessible to employees during each shift?

3. Hazard Classification Changes

  • Have any chemicals in your inventory been reclassified under revised Appendices A–D?
  • Have internal hazard assessments been updated accordingly?

4. Employee Training

  • Have employees been trained on updated label elements and SDS revisions?
  • Does your training reflect current HCS language — not the 2012 version?

Don’t Assume You’re Covered

One of the biggest risks with any regulatory update is assuming that because you reviewed the changes once, the work is complete.

The hazard communication deadline represents more than a paperwork update. It ensures that chemical hazards are classified accurately, communicated clearly, and understood by the employees who work with them daily.

Hazard Communication remains one of OSHA’s most frequently cited standards. As compliance dates pass, enforcement expectations increase.

Missed Our Original Breakdown?

If you need a refresher on what changed, we encourage you to revisit our previous article or you can review OSHA’s Hazard Communication Requirements here.

  • Definition updates
  • Small container labeling provisions
  • Bulk shipment alignment
  • Trade secret concentration changes
  • Appendix revisions

Need a Program Review Before the Hazard Communication Deadline?

If you’re unsure whether your written program, labeling system, SDS library, or employee training fully reflect the updated standard, our team can help review and identify gaps before they turn into citations.

For questions or assistance with your Hazard Communication program, contact Cardinal Compliance Consultants.



from Cardinal Compliance Consultants https://cardinalhs.net/blog/the-hazard-communication-deadline-is-here/
via Cardinal Compliance Consultants

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