OSHA’s revised Hazard Communication Standard is entering its next major compliance phase. Now is the time to ensure employees can navigate updated hazard information.

• By David Kopf
• Aug 06, 2026

Before OSHA’s revised Hazard Communication Standard (HCS) was finalized, many safety professionals viewed implementation as a future task. Today, it’s very much a present-day responsibility. While the revised standard officially took effect on July 19, 2024, compliance is being phased in over several years, creating a transition period in which employers may encounter both legacy and revised labels and Safety Data Sheets (SDSs) throughout their facilities.

That makes 2026 an important year for workplace chemical safety. Manufacturers, importers and distributors were required to update labels and SDSs for substances by May 19, 2026, and employers now have until November 20, 2026, to update workplace labeling, written Hazard Communication programs and employee training as necessary. Compliance deadlines for chemical mixtures extend into 2027 and 2028, but organizations shouldn’t view those dates as permission to wait. Instead, they should make sure they have both their dates and their ducks in a row.

OSHA's revised HCS aligns the United States primarily with Revision 7 of the Globally Harmonized System of Classification and Labelling of Chemicals (GHS), along with select elements of Revision 8, promoting greater consistency in how chemical hazards are classified and communicated. While many of the core elements of HazCom remain unchanged — including labels, SDSs and employee training — the revised standard updates hazard classifications, labeling requirements and SDS content to reflect the latest internationally recognized practices.

For many employers, however, the most noticeable change isn’t the regulation itself—it’s the gradual appearance of updated labels and SDSs arriving from suppliers. During the transition, workers may encounter both previous and revised versions of hazard information depending on when products were manufactured or distributed. That makes effective communication and training especially important.

The November 20 employer deadline is more than an administrative milestone. It represents an opportunity to review the entire Hazard Communication program rather than simply updating paperwork.

A thorough review should begin with the written HazCom program itself. Is it current? Does it accurately reflect the chemicals used throughout the facility? Does it describe how labels are maintained, how SDSs are managed and how employees receive training? Generic template programs should be updated to reflect site-specific practices and responsibilities.

This article originally appeared in the July/August 2026 issue of Occupational Health & Safety.

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