Updated April 2026. Reflects the January 15, 2026 OSHA final rule extending HazCom 2024 compliance deadlines by four months, the 2026 OSHA penalty schedule, and current 29 CFR 1910.1200 requirements.
Reviewed for regulatory accuracy by the OSHA Courses Pro compliance team. Last verified against 29 CFR 1910.1200, Federal Register 89 FR 44144, and the January 15, 2026 extension rule: April 22, 2026.
KEY TAKEAWAYS OSHA published the HazCom 2024 final rule on May 20, 2024, bringing 29 CFR 1910.1200 into conformity with GHS Revision 7. On January 15, 2026, OSHA extended all compliance deadlines by four months. Substances: May 19, 2026 (manufacturers), November 20, 2026 (employers). Mixtures: November 19, 2027 (manufacturers), May 19, 2028 (employers). Changes affect 94% of SDSs and 64% of shipped container labels. HazCom penalties: $16,550 serious, $165,514 willful. |
A chemical distributor ships a solvent with a 2012-format label. The receiving employer stores it next to a 2024-labeled product. Both look similar; the hazard statements do not. This is the transition period, and it runs until each employer’s compliance date.
After that date, a 2012-format label or SDS on the workplace floor is a citable violation. The 2026 OSHA penalty schedule puts each missed label at $16,550 serious, $165,514 willful.
HazCom 2024 is OSHA’s update to 29 CFR 1910.1200 that brings the Hazard Communication Standard in line with GHS Revision 7 and parts of Revision 8. The final rule published May 20, 2024, took effect July 19, 2024, with compliance phased through May 19, 2028. OSHA extended all deadlines four months on January 15, 2026. |
What is the HazCom 2024 update?
The HazCom 2024 update is OSHA’s revision of 29 CFR 1910.1200 that brings it in line with GHS Revision 7 and elements of Revision 8. It adds one new hazard class (desensitized explosives), new aerosol categories, codifies small container labeling, adds 8 new definitions, and revises SDS content. OSHA estimates the changes affect 94% of SDSs and 64% of shipped container labels. |
The 2012 HCS was built around GHS Revision 3. The 2024 update jumps to Revision 7 with parts of Revision 8, covering twelve years of GHS refinements Europe and Canada adopted long ago. OSHA has also published two correction notices since May 2024 to fix typos. The UN GHS is maintained by UNECE at unece.org/transport/dangerous-goods/ghs.
The standard applies to general industry, shipyard, marine terminal, longshoring, and construction. It covers manufacturers, importers, distributors, and employers. One employee and one hazardous chemical triggers coverage; small employers are not exempt. OSHA maintains the official rulemaking hub at osha.gov/hazcom/rulemaking.
The 4 HazCom 2024 compliance deadlines (extended January 2026)
OSHA extended all HazCom 2024 compliance deadlines by four months on January 15, 2026, because the agency could not complete its guidance documents in time. The new deadlines: manufacturers of substances by May 19, 2026; employers using substances by November 20, 2026; manufacturers of mixtures by November 19, 2027; employers using mixtures by May 19, 2028. |
Party | Original deadline | Extended deadline (Jan 2026) |
Manufacturers/importers/distributors of substances | Jan 19, 2026 | May 19, 2026 |
Employers using substances (update labels, program, training) | Jul 20, 2026 | Nov 20, 2026 |
Manufacturers/importers/distributors of mixtures | Jul 19, 2027 | Nov 19, 2027 |
Employers using mixtures (update labels, program, training) | Jan 19, 2028 | May 19, 2028 |
OSHA published the extension in Docket OSHA-2019-0001, invoking the good cause exception under 5 U.S.C. 553(b)(B). The agency had not completed guidance documents in time. Full text of the May 2024 final rule: federalregister.gov/documents/2024/05/20/2024-08568.
THE TRANSITION RULE Between May 20, 2024 and your applicable compliance date, you may use the 2012 HCS, the 2024 HCS, or both simultaneously. Mixed SDS libraries are legal during this transition per 1910.1200(j)(4). After your compliance date, every SDS and label on site must reflect the 2024 standard. |
What changed in GHS labeling requirements?
GHS labeling changes in HazCom 2024 include one new hazard class (desensitized explosives), a new hazard category (chemicals under pressure within aerosols), flammable gas subcategories 1A and 1B, aerosol categories 1 to 3, codified small container labeling (100mL and 3mL thresholds), and DOT pictogram relief. Desensitized explosives now appear in the flame pictogram; HNOC hazards appear in the exclamation mark pictogram. |
- Desensitized explosives, new hazard class from GHS Revision 7 (categories 1 through 4)
- Chemicals under pressure, new category within aerosols class from GHS Revision 8
- Flammable gases, subcategories 1A and 1B added; pyrophoric gases moved under this class
- Aerosols, categories 1, 2, and 3 (including non-flammable aerosols)
- Desensitized explosives now appear in the flame pictogram; HNOC in the exclamation mark pictogram
- Where a DOT pictogram appears on a shipped container for a hazard, the HCS pictogram for the same hazard is no longer required
- Bulk shipment labels may appear on the immediate container or be transmitted via shipping papers, bills of lading, or electronic means
SDS requirements 2024: section-by-section
HazCom 2024 changes affect SDS Sections 1, 2, 3, 9, and 10. Section 1 requires a US domestic address and phone number from manufacturers. Section 2 must address chemical reaction products from anticipated uses. Section 3 trade secret ranges must use OSHA’s prescribed narrowest range. Section 9 adds particle characteristics for solids. Section 10 must include hazards from foreseeable emergencies. |
SDS section | HazCom 2024 change | What to check |
Section 1: Identification | US domestic address and phone required | Reject SDSs listing only foreign addresses |
Section 2: Hazards | Must include reaction products from anticipated uses | Verify reaction hazards for your process |
Section 3: Composition | Trade secret ranges must use narrowest prescribed range | Check for vague concentration ranges |
Section 9: Physical properties | Particle characteristics for solids; matches GHS Rev 7 | Confirm particle data for solid products |
Section 10: Stability/reactivity | Must address hazards from foreseeable emergencies | Verify emergency hazard scenarios covered |
“Some of the most impactful updates affect how manufacturers of hazardous chemicals classify their chemical products. No matter where you are in the chemical supply chain, you have four months longer now than you originally did to comply with updated HazCom requirements.” — Phil Molé, MPH, Principal EHS and Sustainability Expert, VelocityEHS, January 2026 |
HazCom 2012 vs 2024: what actually changed
HazCom 2012 was built around GHS Revision 3. HazCom 2024 matches GHS Revision 7 plus parts of Revision 8. Key differences: one new hazard class, updated aerosol categories, codified small container rules, US domestic address required on SDSs, narrowest trade secret ranges, and DOT pictogram relief. The 16-section SDS structure and core training requirements did not change. |
Element | HazCom 2012 | HazCom 2024 |
GHS alignment | Revision 3 | Revision 7 + parts of Rev 8 |
Hazard classes | Original GHS set | + Desensitized explosives |
Aerosol categories | Categories 1, 2 | Categories 1, 2, 3 |
Chemicals under pressure | Not a category | New category in aerosols class |
Small container rule | Guidance only | Codified: 100mL and 3mL |
SDS Section 1 address | Address required | US domestic address + phone |
SDS Section 3 trade secret | Ranges allowed | Prescribed narrowest range |
SDS Section 9 | Property list | + Particle characteristics for solids |
DOT pictograms on shipped containers | HCS pictogram still required | HCS pictogram not required for same hazard |
Pyrophoric gases | Separate hazard class | Under flammable gases class |
Definitions | Original set | + 8 new terms |
The 7 required elements of a compliant written HazCom program
A compliant written HazCom program under 29 CFR 1910.1200(e) must include seven elements: scope and responsibilities, chemical inventory, SDS management, container labeling, employee training, non-routine tasks, and multi-employer coordination. The program must name specific individuals responsible for each element and be accessible to employees during every shift. |
# | Element | What it must include |
1 | Scope and responsibilities | Named person responsible for the program, applicability to each worksite |
2 | Chemical inventory | List of every hazardous chemical on site, tied to product identifiers |
3 | SDS management | Where SDSs are stored, how employees access them on every shift |
4 | Container labeling | Shipped container system, workplace/secondary container system, unlabeled pipes |
5 | Employee training | Initial training before exposure, retraining triggers, documentation |
6 | Non-routine tasks | Tasks performed occasionally with different chemical exposures (confined space entry, tank cleaning) |
7 | Multi-employer coordination | How contractors and host employers share SDSs and hazard information |
Secondary container labeling is one of the most frequently cited HazCom violations. Generic training that fails to name specific chemicals at your site is the second. OSHA expects specificity tied to your workplace, your chemicals, your procedures. The American Industrial Hygiene Association (aiha.org) publishes written program guidance matched to the 2024 rule.
Train your team on HazCom compliance in 32 minutes. Hazard Communication (US) is $29.95 (was $59.99). Covers labels, SDSs, pictograms, and the 2024 GHS Revision 7 update. IACET-accredited, OSHA-recognized, DOL-approved. Instant certificate on completion. Enroll → oshacoursespro.com |
Do you need to retrain your whole workforce?
For most employers, the answer is no. The 2024 HCS did not change the training provisions at 29 CFR 1910.1200(h). However, employers must provide additional training for employees exposed to newly identified physical, health, or other hazards by their compliance date. Workers exposed only to chemicals unaffected by reclassification need no new training. |
The 2012 HCS update was a rebuild; the 2024 update is a refresh. Employers running a compliant HazCom program need targeted retraining, not a workforce-wide reset.
Your situation | Retraining required? |
Worker exposed to aerosols, desensitized explosives, or chemicals under pressure | Yes, on new hazard categories and pictograms |
Worker exposed to chemicals with updated SDS Section 2, 3, 9, or 10 information | Yes, on changes relevant to their work |
Worker exposed only to chemicals unaffected by reclassification | No, existing training stands |
New hire after compliance date | Yes, must receive current HazCom training before exposure |
Training materials predate the 2024 rule | Yes, update materials, then retrain affected workers |
Training under 1910.1200(h) must be hazard-specific and provided before exposure, not within 30 days. Retraining triggers: new chemicals, process changes, standard updates. No training record reads as no training.
What to do right now: action by deadline
By May 19, 2026, chemical manufacturers must reclassify affected substances and ship updated labels and SDSs. By November 20, 2026, employers using substances must receive updated SDSs, update workplace labels, revise the written program, and retrain affected workers. Mixture deadlines fall November 19, 2027 and May 19, 2028. |
Deadline | Party | Required actions |
May 19, 2026 | Manufacturers (substances) | Reclassify substances under GHS Rev 7; update SDS Sections 1, 2, 3, 9, 10; add US domestic address to Section 1; issue revised shipped labels; notify distributors |
November 20, 2026 | Employers (substances) | Confirm receipt of updated SDSs; replace workplace/secondary labels; revise written program; retrain affected workers; document training (date, topics, trainer, attendees) |
November 19, 2027 | Manufacturers (mixtures) | Complete reclassification work for all mixtures; issue updated SDSs and shipped container labels |
May 19, 2028 | Employers (mixtures) | Complete SDS replacement, label updates, program revision, and training for mixtures. Final date all chemicals on site must reflect 2024 standards |
Common HazCom violations and 2026 OSHA penalties
HazCom ranks as the second most-cited OSHA general industry standard, with over 2,500 violations written annually. The 2026 OSHA penalty schedule assesses up to $16,550 per serious violation and $165,514 per willful or repeat violation. Each missing SDS, unlabeled secondary container, or untrained exposed worker can be cited separately. |
Violation | Regulation | Serious penalty | Willful penalty |
No written HazCom program | 1910.1200(e)(1) | $16,550 | $165,514 |
Missing or outdated SDS | 1910.1200(g) | $16,550 | $165,514 |
Untrained employees exposed to hazardous chemicals | 1910.1200(h)(1) | $16,550 | $165,514 |
Unlabeled workplace or secondary containers | 1910.1200(f)(6) | $16,550 | $165,514 |
Outdated SDS after compliance date | 1910.1200(j) | $16,550 | $165,514 |
No chemical inventory | 1910.1200(e)(1)(i) | $16,550 | $165,514 |
HazCom has sat in OSHA’s Top 5 most-cited general industry standards for a decade. Treat every element as an audit target.
INSPECTOR’S PERSPECTIVE In the field, HazCom citations cluster around three failures: unlabeled secondary containers on break-room tables or workbenches, training records that list ‘HazCom’ without naming specific chemicals, and SDS libraries stored on a shared drive nobody remembers the login for. Compliance officers check these three first. Passing those three passes most HazCom inspections. |
“Aligning the HCS with the GHS has had a positive impact on workplace hazard communication. Data from published studies indicate that the hazard communication approach taken in the 2012 HCS has been effective in enabling workers to understand, avoid, and mitigate exposures to hazardous chemicals in the workplace.” — OSHA Final Rule preamble, Hazard Communication Standard, 89 FR 44144, May 20, 2024 |
What to do when your supplier has not sent updated SDSs
If your supplier has not sent updated SDSs before your compliance date, you remain liable. OSHA does not excuse downstream employers for supplier noncompliance. Document every supplier contact, request in writing, and escalate. After your compliance date, you must either obtain compliant documentation or stop using the product. |
The transition rule protects you until your compliance date. After that, a 2012-format SDS in your library reads as noncompliance. The legal burden sits with the employer using the chemical.
The supplier verification checklist
- When will you send us updated 2024-compliant SDSs for every product we purchase?
- Which of your products fall under the new aerosol, desensitized explosives, or chemicals under pressure categories?
- Does your SDS Section 1 include a US domestic address and phone number?
- Have you updated Section 3 trade secret ranges to OSHA’s prescribed narrowest range?
- Will updated shipped container labels arrive with the next order or separately?
- What is your commitment date for full HazCom 2024 compliance across your catalog?
DOCUMENT EVERYTHING Email every supplier in writing. Save their replies. If a supplier fails to deliver compliant documentation before your deadline, your email trail proves good-faith effort. Good-faith documentation can reduce citation severity from willful to serious, a $148,964 swing per violation. |
Small container labeling: the 100mL and 3mL rules
HazCom 2024 codifies small container labeling exemptions. Containers of 100 milliliters or less may use abbreviated labels if full labeling is not feasible. Containers of 3 milliliters or less require only the product identifier on the immediate container, provided the outer package carries full GHS labeling. Labs, medical facilities, salons, and research settings rely on these rules. |
Container size | Labeling requirement | Example |
More than 100 mL | Full GHS label required | 32 oz cleaner bottle, 1 L solvent jug |
100 mL or less | Abbreviated label permitted if full label not feasible | 50 mL essential oil, 100 mL reagent bottle |
3 mL or less | Product identifier only on immediate container; full GHS on outer package | 2 mL pipette, perfume sample, ampoule |
The exemption is conditional, not automatic. A 100 mL bottle with flat sides and room for full text does not qualify. The abbreviated label must still include the product identifier and signal words.
HazCom training done the right way
OSHA 29 CFR 1910.1200(h) requires hazard communication training before an employee’s first exposure to hazardous chemicals. Training must cover labels, SDSs, physical and health hazards of each chemical, protective measures, and the location of the written program. Retraining is required when new chemicals arrive, processes change, or the standard updates. |
OSHA Courses Pro delivers IACET-accredited, OSHA-recognized, DOL-approved HazCom training across five short courses and the OSHA 10 and 30 General Industry Outreach programs:
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$29.95 | 9 min | |
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Hazardous Chemical Information Awareness | $29.95 | 12 min |
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Frequently Asked Questions
What is OSHA HazCom 2024?
HazCom 2024 is OSHA’s May 20, 2024 final rule updating 29 CFR 1910.1200 to bring it in line with GHS Revision 7 and parts of Revision 8. It took effect July 19, 2024.
When is the HazCom 2024 compliance deadline?
After the January 15, 2026 extension: substances manufacturers May 19, 2026; substances employers November 20, 2026; mixtures manufacturers November 19, 2027; mixtures employers May 19, 2028.
Do I need to retrain every employee on HazCom 2024?
No. The 2024 HCS did not change training provisions at 1910.1200(h). Only workers exposed to chemicals in newly classified hazard categories need targeted retraining.
Can I still use 2012-format SDSs?
Yes, until your compliance date. The transition rule at 1910.1200(j)(4) permits 2012 HCS, 2024 HCS, or both during the phase-in. After your date, all SDSs must reflect 2024 requirements.
What changed on the SDS under HazCom 2024?
Sections 1, 2, 3, 9, and 10. Section 1 now requires a US domestic address and phone. Section 3 requires narrowest trade secret ranges. Section 9 adds particle characteristics.
What are the 2026 OSHA fines for HazCom violations?
Up to $16,550 per serious violation and $165,514 per willful or repeat violation. Each missing SDS, unlabeled container, or untrained exposed worker can be cited separately.
What is the small container labeling rule?
Containers of 100 mL or less may use abbreviated labels. Containers of 3 mL or less require only the product identifier, provided the outer package carries full GHS labeling.
Which OSHA Courses Pro course covers HazCom 2024?
Hazard Communication (US) at $29.95 covers the full standard in 32 minutes. OSHA 10 General Industry ($59) and OSHA 30 General Industry ($189) cover HazCom as part of full Outreach training.
