OSHA Extends HCS Compliance Deadlines: What You Need to Know

Background

In May 2024, OSHA updated the Hazard Communication Standard (HCS, 29 CFR 1910.1200), aligning it with GHS Revision 7 to improve hazard classification, labels, and Safety Data Sheets (SDSs). Original compliance deadlines ranged from January 2026 to January 2028, depending on whether your US Company manufactures, imports or distributes pure substances or mixtures. 

Why the Extension?

OSHA announced a four-month extension in response to feedback from industry stakeholders who highlighted the need for additional time to digest new guidance and implement changes effectively. Click here to view the notice.

Revised Compliance Deadlines

What This Means for You

Manufacturers, Importers and Distributors (Substances)

You now have until May 19, 2026 to: 

• Update SDSs with new hazard classes and minimum required information
• Update labeling requirements, including small containers.

Employers Handling Substances: By November 20, 2026, these items will need to be revised:

• Workplace labels
• Written HazCom programs
• Refresh employee training to cover new classifications and label information

Manufacturers, Importers and Distributors (Mixtures)

You now have until November 19, 2027 to align mixture-related labels and SDSs with the updated standard and guidance.

Employers Handling Mixtures: By May 19, 2028, update internal programs, labels, and training accordingly.

Strategic Action Plan

1. Inventory review & prioritization 

• Focus first on pure substances, targeting completion by May 2026.
• Follow with mixtures before the November 2027 deadline.

2. Update Safety Data Sheets & labels 

• Incorporate new hazard classes, pictograms, and signal words.
• Use permitted concentration ranges and small-container labeling flexibility.

3. Revise HazCom Programs and Training 

• Finalize updates by Nov 20, 2026 (substances), and May 19, 2028 (mixtures).
• Deliver targeted employee training tied to classification changes.

4. Stay Informed 

• Monitor OSHA guidance materials expected in the coming weeks.
• Leverage updated references to avoid non-compliance errors.

Why It Matters

These extensions are not a grace period; they are a critical opportunity. OSHA does not anticipate reprieves after May. Non-compliance risks include citations, workplace hazards, and disrupted supply chains.

Final Thoughts

This four-month extension gives your organization vital opportunity to complete updates, but the clock is still ticking. Use it wisely: update SDSs, relabel products, revise your HazCom program, and train staff. Proactive compliance allows for regulatory alignment and protects your workforce!

How can CHEMTREC help?

SDS Management

SDS Authoring: Streamline compliance and boost productivity—let CHEMTREC create/update your SDS and GHS labels to meet HazCom 2024 standards, so your team can focus on what matters most: running your business.

SDS Access and Distribution: Allows your company to stay compliant with OSHA regulations by providing employees and downstream users with readily accessible SDS.
 

Training

Explore our Learning Academy courses including OSHA’s updated Hazard Communication Standard (HCS) for employees to be well equipped with all the updated knowledge and insight on the classification, labeling and training of hazardous chemicals.