Employers have until Nov. 20 to bring their workplace labels, written hazard communication programs and training in line with OSHA’s updated Hazard Communication Standard for substances. That’s the first employer deadline under the 2024 HazCom rewrite, and on a jobsite it lands on every contractor that keeps chemicals on hand.
Occupational Health & Safety flagged the approaching date on Oct. 8. It wasn’t always Nov. 20. OSHA pushed every compliance date back four months in a final rule last January, saying its own guidance materials weren’t ready in time for the first deadline. The employer date for substances moved from July 20 to Nov. 20.
What the HazCom deadline requires of contractors
Construction doesn’t get a separate version. The construction standard at 29 CFR 1926.59 points straight to the general industry rule at 1910.1200, so the same dates apply to a GC’s trailer and a sub’s gang box.
By Nov. 20, employers need to have done four things for substances:
Check that suppliers have sent updated safety data sheets, and read them for newly classified hazards. Update any workplace labels, including secondary containers, so they match. Revise the written HazCom program. Train workers on the new hazards before the deadline, not after.
Manufacturers, importers and distributors had to finish reclassifying substances and updating labels and SDSs by May 19. If a supplier hasn’t sent new sheets, that’s the first call to make.
What changed in the Hazard Communication Standard
The 2024 update aligns OSHA’s rule with Revision 7 of the UN’s Globally Harmonized System. It adds a hazard class for desensitized explosives, reworks the criteria for flammable gases and aerosols, and adds labeling relief for small containers. Most of it is upstream work for chemical makers. The employer piece is making sure what arrives on site is labeled, filed and explained correctly.
Construction’s problem is that the chemicals keep moving. Sealants, adhesives, coatings and fuels come and go with each trade, and the crew working next to a product often isn’t the one that brought it. That’s the gap behind the push for training workers on other trades’ hazards, and HazCom is the paperwork version of the same issue.
The next HazCom compliance dates
The mixtures deadlines are still ahead. Manufacturers, importers and distributors must comply for mixtures by Nov. 19, 2027, and employers have until May 19, 2028, to update labels, programs and training for those products. Since most construction products are mixtures, the 2028 date is the one that’ll touch more of the SDS binder.
Until each date passes, employers can comply with the 2012 version of the standard, the updated one or both. States that run their own OSHA plans may set different timelines, so contractors working across state lines should check each one.
HazCom has sat near the top of OSHA’s most-cited standards for years, and it’s usually cited for missing programs and training, not exotic chemistry. A dated training roster with the new hazards on it is the cheapest compliance document a contractor will produce this year.