First HazCom compliance date just around the corner

OSHA’s updated Hazard Communication standard took effect July 19, 2024, and included staggered compliance dates stretching into 2028. The first of these compliance dates is just around the corner.

By January 19, 2026, manufacturers, importers, and distributors evaluating substances must be in compliance with all modified provisions of 29 CFR 1910.1200. (Substance is defined in 1910.1200(c).) Such manufacturers and importers must reclassify aerosols, desensitized explosives, and flammable gases under the new criteria in Appendix B to 1910.1200 and make corresponding updates to safety data sheets (SDSs) and labels.

In addition, these manufacturers, importers, and distributors must comply with the following changes, as applicable:

• Labels for packages released for shipment (1910.1200(f)(11))
• Labels for bulk shipments (1910.1200(f)(5)(ii))
• Labels for small containers (1910.1200(f)(12))
• SDS subsections (Appendix D to 1910.1200)
• Trade secrets (1910.1200(i))

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).

By July 20, 2026, impacted employers, as necessary, must update any alternative (in-house) labeling, update their HazCom training program, and provide additional employee training for newly identified physical, health, or other hazards covered. OSHA says that because the updated HazCom standard contains only limited revisions of the hazard classification rules, it does not anticipate that most employers will need to complete these additional requirements.