Get Your Dates — and Your Ducks — in a Row

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.

Understanding What’s Changing

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.

Don’t Delay

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.

The facility’s chemical inventory should also be reviewed to ensure product names match both SDSs and workplace labels. Consistency matters. Employees should be able to move seamlessly from a product label to its corresponding SDS without confusion caused by different product identifiers or outdated documents.

Labels Matter More Than Ever

One of the most common HazCom deficiencies remains something surprisingly simple: improperly labeled secondary containers.

When chemicals are transferred from their original containers into spray bottles, buckets or other workplace containers, those containers generally require appropriate labeling unless they remain under the immediate control of the employee performing the transfer and are used during the same work shift. Yet missing or incomplete secondary labels continue to be a frequent compliance issue.

As revised labels begin appearing from manufacturers, employers should ensure employees understand not only what the labels say but how to interpret them. Rather than memorizing individual chemicals, workers should understand the meaning of pictograms, signal words, hazard statements and precautionary statements so they can recognize hazards regardless of the specific product.

SDS Management

Maintaining SDSs has long been a cornerstone of Hazard Communication, but accessibility is just as important as availability.

Electronic SDS management systems have become increasingly common, offering faster updates and improved organization. QR codes, cloud-based platforms and mobile access can make information readily available on the production floor. However, employers should verify that employees can access SDSs immediately during normal operations and emergencies without technological barriers. Backup procedures should also exist in case electronic systems become unavailable.

Facilities should also verify that they possess the most current SDS for every hazardous chemical on site. As manufacturers continue updating documentation to comply with the revised HCS, employers should replace outdated SDSs as new versions become available.

Focus on Understanding

Perhaps the most significant opportunity presented by the revised standard is improving the quality of employee training.

Effective Hazard Communication training isn’t about asking employees to memorize regulations or recite every hazard classification. Instead, workers should understand where to find information, how to interpret labels and SDSs, what protective measures apply to the chemicals they use, and what actions to take if conditions change.

Training should also reflect the workforce itself. Facilities with multilingual employees, contractors or temporary workers should ensure hazard information is communicated in a manner employees can understand. While OSHA requires labels and SDSs to be available in English, employers should consider additional resources where language barriers could affect worker comprehension.

Likewise, introducing a new chemical isn’t always what triggers additional training. The determining factor is often whether employees are being exposed to a hazard they have not previously been trained to recognize and control.

A Good Time for a Checkup

With the November 20 deadline approaching, safety professionals have an opportunity to evaluate their HazCom programs before compliance becomes an enforcement issue.

A practical checklist includes:

• Review and update the written Hazard Communication program.
• Verify the facility’s chemical inventory.
• Replace outdated SDSs with revised versions from suppliers.
• Confirm that workplace and secondary container labels are accurate.
• Ensure employees can readily access SDSs.
• Refresh employee training to include updated label and SDS information.
• Document all updates and training activities.

Hazard Communication has always been about more than regulatory compliance. At its core, it ensures workers understand the chemical hazards they face and have the information necessary to protect themselves. As OSHA’s revised standard continues its phased implementation, organizations that keep both their dates and their ducks in a row will be better positioned to meet compliance deadlines while strengthening workplace safety for the long term.

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