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.
The dates
| Date | What OSHA's table says | Who |
|---|---|---|
| May 19, 2026 | Update labels and SDSs for substances | Manufacturers, importers, distributors |
| November 20, 2026 | Update workplace labels, hazard communication program and training as necessary, for substances | Employers |
| November 19, 2027 | Update labels and SDSs for mixtures | Manufacturers, importers, distributors |
| May 19, 2028 | Update workplace labels, program and training as necessary, for mixtures | Employers |
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.
| Chemical | Supplier | Revised SDS received | Hazards 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?
HazCom kit Pro
- Everything in Team
- Audit workbook (.xlsx) with formulas: SDS tracker with status flags (SDS not received, label needed, training needed, done), label sheet that flags containers of 100 ml or less, training roster, and a summary with days to November 20, 2026
- One free update
HazCom kit Team
- Everything in Starter
- Written HazCom program fill in template
- 20 minute training outline with attendance and comprehension record
- Mixtures timeline for November 2027 and May 2028
- One free update
HazCom kit Starter
- SDS reconciliation tracker with CSV export and a blank CSV
- Label checker worksheet, with a section for containers of 100 ml or less
- Compliance file index
Team and Pro include one free update: if the source changes materially, we revise your kit page once, at the same link, at no cost. Templates and checklists only, no outcome guarantee.
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.
Privacy: we store your email address and the time you signed up, nothing else, to send that one email. It is kept on Cloudflare. We do not sell or share it.