When is the HazCom 2024 employer deadline?

The HazCom 2024 deadline for employers is November 20, 2026 for substances and May 19, 2028 for mixtures. By those dates, employers must, as necessary, update any alternative workplace labeling they use, their hazard communication program and their employee training for newly identified hazards. OSHA extended each HazCom 2024 compliance date by four months in January 2026. (29 CFR 1910.1200(j); 91 FR 1695, January 15, 2026)

All four HazCom 2024 compliance dates

Manufacturers, importers and distributors evaluating chemicals have the earlier date in each pair, covering all modified provisions of the standard. All employers, including manufacturers with employees, have the later dates, covering the three tasks below. (29 CFR 1910.1200(j)(2)–(3))

OSHA's later correction notices did not change these dates. (89 FR 81829; 91 FR 562; 91 FR 6760)

What employers must do by the deadline

Three tasks, each required as necessary:

1. Update alternative workplace labels. Any alternative labeling you use on containers in the workplace. (29 CFR 1910.1200(f)(6))
2. Update your hazard communication program. The written program lists your hazardous chemicals and explains how you meet the labeling, safety data sheet and training requirements, and how you will inform employees of the hazards of non-routine tasks and of chemicals in unlabeled pipes. (29 CFR 1910.1200(e)(1); paragraph (j)(2)(ii) cites (h)(1) for this task)
3. Train employees on new hazards. Additional training for any newly identified physical, health or other hazards. (29 CFR 1910.1200(h)(3))

The same three tasks apply to mixtures, due May 19, 2028. (29 CFR 1910.1200(j)(2)(ii) and (j)(3)(ii))

Why employers get six months more

The gap is deliberate. OSHA gave employers "an additional six months after the compliance dates to complete any necessary updates" for newly identified physical or health hazards resulting from the evaluation of substances and mixtures. (89 FR 44303, May 20, 2024)

Can you follow the old standard until then?

During the transition, yes. Manufacturers, importers, distributors and employers may comply with the updated standard, the previous version (the 2012 standard, as codified July 1, 2023), or both, from May 20, 2024 until the dates in (j)(2) and (j)(3), "as applicable". The January 2026 extension did not change this rule. (29 CFR 1910.1200(j)(4), which refers to § 1910.1200 as revised July 1, 2023; 77 FR 17574; 91 FR 1695)

What counts as a workplace label?

Each container of hazardous chemicals in the workplace needs one of two things:

• the label information required on shipped containers, except the supplier's name, address and phone number; or
• the product identifier (its name or number), plus words, pictures or symbols that give at least general hazard information and, together with the rest of your hazard communication program, tell employees the specific physical and health hazards.

(29 CFR 1910.1200(f)(6); shipped-label contents in (f)(1)(i)–(v))

Exceptions: stationary process containers can use signs, placards, process sheets, batch tickets, operating procedures or similar written materials instead of labels, as long as those materials identify the containers they apply to, convey the information (f)(6) requires on a label, and are readily accessible to employees in their work area throughout each work shift. Portable containers filled from a labeled container, and intended only for the immediate use of the employee who fills them, need no label. ((f)(7); (f)(8))

A five-step checklist

1. Sort your chemicals into substances and mixtures. Substances are due November 20, 2026; mixtures May 19, 2028.
2. Check whether updated classifications from your chemical manufacturers or importers identify new hazards, and decide which alternative workplace labeling, written-program and training updates are necessary. Any additional training, as necessary, covers newly identified physical, health or other hazards. ((j)(2)(ii); (j)(3)(ii); (d)(1))
3. Update any alternative workplace labels where a hazard has changed. (f)(6)
4. Update the written program, including the list of hazardous chemicals. (e)(1)
5. Train employees on the new hazards. (h)(3)

Make the workplace labels

The Workplace Label Generator lays out a workplace label from the H-codes in Section 2 of a safety data sheet, in formats for US OSHA (HazCom 2024), Canada WHMIS or UN GHS Rev.10. The 2024 update amended the HCS "to conform to the United Nations' Globally Harmonized System of Classification and Labelling of Chemicals (GHS), primarily Revision 7 (Rev. 7)". (89 FR 44144) Containing GHS label elements does not by itself make a label compliant; check it against (f)(6) for your containers.