OSHA updated its Hazard Communication Standard (HazCom) in 2024, and the revisions are reaching their compliance deadlines in 2026. Contractors will need to revise their HazCom programs and training by July 2026 to be compliant. We’ve put together this guide so contractors will know exactly what’s been updated, how it affects them, and what they need to do to remain in compliance.
The final rule update for OSHA’s Hazard Communication Standard was published on May 20, 2024, with an effective date of July 19, 2024. Compliance deadlines are based on the effective date, and are as follows:
- Substance manufacturers - 18 months (deadline January 19, 2026)
- Mixture manufacturers - 36 months (deadline July 19, 2027)
- Employers have 6 months after these deadlines to change their HazCom practices (labels, plan, worker training)
Based on the above effective dates and deadlines, contractors need to review and update their HazCom programs by July 20, 2026, and January 19, 2028.
Final rule changes
While the HazCom final rule changes mainly affect chemical manufacturers and distributors, contractors need to pay attention as well, as they must update their HazCom programs and training to reflect the revisions.
The final rule changes include:
Changes to hazard categories, including establishing new hazard categories:
- Chemicals under pressure (under aerosols)
- Desensitized explosives
- Flammable gases (adding two subcategories)
Added required pictograms, hazard signal words, and hazard statements for the revised/new hazard categories
- Pictograms are the icons on the product label that signify the type of hazard.
- Hazard signal words include “Danger,” “Warning,” and “Caution.”
- Hazard statements define the potential danger, such as “Flammable chemical under pressure; may burst if heated.”
Revised section 9 of safety data sheets (SDS) to include particle characteristics
- Updates to container labeling requirements for small (100 mL or less) and very small (3 mL or less) containers
- Manufacturers must provide a US domestic address and phone number in section 1 of each SDS
Basic tenets of the OSHA HazCom standard
OSHA’s Hazard Communication Standard requires employers to provide information to their employees about the potentially hazardous chemicals and materials they may be required to handle while performing their duties. This is done through the development and implementation of a hazard communication plan, and subsequent training for employees on the plan and how to access the information they need in case of an emergency.
For construction contractors, this means they must:
- Maintain a chemical inventory for each site
- Maintain a site-specific SDS library that is accessible to all workers
- Ensure proper labeling of all containers of hazardous chemicals
- Develop a written HazCom plan, including site-specific access to SDS, methods of HazCom training, and container labeling practices
- Provide worker training on the company’s HazCom plan, accessing and reading SDS, and specific chemical hazards
If your company doesn’t have a HazCom plan in place, check out OSHA’s fact sheet: Steps to an Effective Hazard Communication Program for Employers That Use Hazardous Chemicals, or their more detailed guide: Hazard Communication: Small Entity Compliance Guide for Employers That Use Hazardous Chemicals.
What contractors need to do between now and July 20, 2026
- Update the hazardous chemical inventory for each work site, including all hazardous substances and mixtures you use and store on site.
- Update your SDS library for all the chemicals in your inventory.
- Ensure all workers have immediate, right-to-know access to your SDS library.
- Confirm receipt of updated SDSs and container labels for products affected by the final rule update (aerosols, chemicals under pressure, desensitized explosives, and flammable gases). Manufacturers have until January 19, 2026, to provide them.
- Update your HazCom practices accordingly, including your: written HazCom plan and workplace labeling system
- Train workers on the changes to the chemical classifications and hazard information (hazard pictograms, signal words, hazard statements, and precautionary statements).
