First HazCom compliance date almost here!

OSHA’s revised Hazard Communication (HazCom) standard, which took effect in July 2024, includes staggered compliance dates stretching into 2028. The first of these is just around the corner. By May 19, 2026, chemical manufacturers, importers, and distributors evaluating substances must be in compliance with all modified provisions of the standard. (“Substance” is defined in 1910.1200(c).) This means manufacturers and importers must reclassify aerosols, desensitized explosives, and flammable gases under the new criteria in Appendix B to 1910.1200 and make corresponding changes to safety data sheets (SDSs) and labels.

Additionally, these manufacturers, importers, and distributors must comply with changes to the following elements, as applicable:

• Labels for packages released for shipment, bulk shipments, and small containers;
• SDS subsections; and
• Trade secrets.

Downstream users of substances that are aerosols, desensitized explosives, or flammable gases will start to see updated SDSs and labels on shipped containers of hazardous chemicals (if they haven’t already). For more information, see our related FAQ.