OSHA Extends Hazard Communication Standard (HCS) Compliance Deadlines — Including SDS Updates

On January 15, 2026, the U.S. Occupational Safety and Health Administration (OSHA) published a final rule in the Federal Register extending compliance dates for its 2024 updates to the Hazard Communication Standard (HCS). 

The updated HCS was designed to better align OSHA’s requirements with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). It included changes to hazard classification criteria and hazard communication elements (labels and SDS content). 

As the initial compliance deadlines approached, OSHA determined that more time was needed to publish finalized guidance materials for the regulated community. To provide regulated entities adequate time to prepare and review guidance before the revised provisions take effect, OSHA extended all major HCS compliance deadlines by four months 

New Compliance Deadlines: 

 

Initial deadline 

New deadline 

Manufacturers, importers, and distributors evaluating substances 

January 19, 2026 

May 19, 2026 

Employers (workplace labeling and training) for substances 

July 20, 2026 

November 20, 2026 

Manufacturers, importers, and distributors evaluating mixtures 

July 19, 2027 

November 19, 2027 

Employers (workplace labeling and training) for mixtures 

January 19, 2028 

May 19, 2028 

 

During this interim period, covered entities may comply with either the previous 2012 HCS, the 2024 revised HCS, or a combination of both, until the applicable extended compliance dates arrive.  

If you are unsure whether your product is classified as a substance or a mixture, or need support with SDS authoring and hazard classification under OSHA and GHS requirements, contact Dell Tech to ensure your SDSs and labels are accurate, up to date and fully compliant. 

 


DELL TECH HAS PROVIDED PROFESSIONAL, CONFIDENTIAL CONSULTING SERVICES TO THE SPECIALTY CHEMICAL INDUSTRY IN CANADA, THE USA, EUROPE AND ASIA FOR THE LAST 40 YEARS.   

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