By Adam R. YoungDaniel R. Birnbaum, and Craig B. Simonsen

Seyfarth Synopsis: The Occupational Safety and Health Administration’s (“OSHA”) Hazard Communications (“HazCom”) Standard was the most frequently cited general industry standard in the past fiscal year.  OSHA recently announced a final rule that will update the current HazCom Standard to require new information on Safety Data Sheets and labels. The updated standard takes effect on July 19.

Image from OSHA.

OSHA’s HazCom Standard, the most frequently cited general industry standard, is being updated to align with the United Nations’ Globally Harmonized System of Classification and Labelling of Chemicals.  The updated standard includes revised criteria for classification of certain health and physical hazards, revised provisions for updating labels, new labeling provisions for small containers, new provisions related to trade secrets, technical amendments related to the contents of safety data sheets (SDSs), and related revisions to definitions of terms used in the standard.

Chemical manufacturers, importers and distributors have until January 19, 2026 or July 19, 2027 to comply with the new rules.  The compliance deadline will depend on whether they are evaluating substances or mixtures.

Employers who use products that fall under the standard must revise their HazCom programs, labels and training by July 20, 2026 or January 19, 2028, subject to whether they are using substances or mixtures.

Given the prevalence of products that fall under this standard and the frequency of HazCom citations, employers should use this announcement as an opportunity to review their HazCom programs and develop a plan to ensure compliance by the respective deadline.  Employers should consult experienced OSHA counsel to help review their HazCom program and limit their exposure.