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HazCom employer deadline: November 20, 2026

If your workers handle hazardous chemicals, OSHA's updated Hazard Communication Standard asks employers to update workplace labels, the written program and training for substances by this date. This page gives you the dates, a nine step checklist and a small SDS tracker. Everything runs in your browser and saves nothing to a server.

--days from today to November 20, 2026 (counted in your browser)
Checklist and templates, not legal advice. We are not affiliated with OSHA. Rules and dates can change and state plan states can differ. Check the primary sources linked below and ask a qualified adviser about your own site.

The dates

DateWhat OSHA's table saysWho
May 19, 2026Update labels and SDSs for substancesManufacturers, importers, distributors
November 20, 2026Update workplace labels, hazard communication program and training as necessary, for substancesEmployers
November 19, 2027Update labels and SDSs for mixturesManufacturers, importers, distributors
May 19, 2028Update workplace labels, program and training as necessary, for mixturesEmployers

Source: OSHA, Questions and Answers for OSHA's 2024 Update to the HCS, and the compliance date extension notice (January 15, 2026 extension, 91 FR 1695). Some state plan states may differ from the federal dates.

Nine step checklist

These steps follow the action lists in two law firm summaries (Shipman and Goodwin, Robinson and Cole in National Law Review). They are suggestions from those firms, not OSHA requirements by themselves.

Free mini SDS tracker

List each substance you use. Tick what you have confirmed. Saved in this browser only. The kit has the full version with CSV export and the label checker.

ChemicalSupplierRevised SDS receivedHazards changed?Labels updated

Small containers

OSHA says the 2024 update added special labeling provisions for small packages of 100 ml or less, and for very small packages of 3 ml or less (OSHA publication 4437, 2024 final rule). The National Law Review summary tells employers to check small containers against these provisions. Read paragraph (f)(12) of 29 CFR 1910.1200 for the exact text. Do not rely on this page for the details.

Want it ready to print?

What is at stake. Both law firm summaries we cite say serious OSHA violations can carry penalties of up to $16,550 each and willful or repeat violations up to $165,514, and that an inspection can produce several citations when there are many containers or an outdated program or training record. The employer date for substances is November 20, 2026, which is about four weeks from this page being written. Sources: Shipman and Goodwin, Robinson and Cole. Penalty amounts change, so check OSHA for current figures.
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Get the mixtures guide

We plan to publish a guide for the mixtures phase (November 2027 and May 2028). Leave your email and we will send one email when it is ready. No other mail, no sharing your address. Unsubscribe any time with the link, at /unsubscribe, or reply STOP to fuseini.metadata@gmail.com.

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