OSHA’s 2024 Hazard Communication Standard changes supplier labels and safety data sheets. Employers must review updated records while keeping workplace labels, training, and employee access current.
Quick Answer: The rule mainly aligns OSHA’s standard with GHS Revision 7. It adds hazard classes, revises SDS Sections 2, 3, 9, and 11, and clarifies small-container labels. After OSHA’s 2026 extension, employers must complete necessary substance updates by November 20, 2026. The mixture deadline is May 19, 2028.
Table of Contents
- What changed in OSHA’s 2024 HazCom rule?
- What changed in GHS safety data sheets?
- Which compliance dates apply now?
- What must an employer that uses chemicals do?
- How do labels and training change?
- How Helios Comply helps
- Frequently asked questions
- Sources
What changed in OSHA’s 2024 HazCom rule?
OSHA published the final rule on May 20, 2024. It took effect on July 19, 2024, and mainly aligns the standard with GHS Revision 7. Revised criteria cover desensitized explosives, flammable gases, aerosols, and skin or eye effects.
Manufacturers and importers must consider physical-form changes and reaction products from known or reasonably anticipated uses. They need not assess every conceivable use. Employers that only use purchased chemicals can rely on supplier classifications, but they still own their duties under OSHA’s HazCom requirements. Helios Comply can organize SDS records by location. It does not replace the employer’s hazard assessment or written program.
What changed in GHS safety data sheets?
OSHA revised SDS Sections 2, 3, 9, and 11, but kept the 16-section order. Suppliers that classify products must update their SDSs. A downstream employer gets the current document, matches it to the product, and examines workplace effects.
Section 2: Hazard identification
Section 2 lists classified hazards and label elements. Preparers now consider hazards from intrinsic properties, physical-form changes, and reaction products from known or reasonably anticipated uses. Use-related hazards belong in Section 2, but not necessarily on the shipped-container label. Employers must compare a revision with local labels, procedures, controls, and training. Helios Comply can organize the SDS by location. The employer decides how it affects the work.
Section 3: Composition and ingredient information
A supplier that protects an exact concentration as a trade secret must use a prescribed range. It must use the narrowest permitted range that contains the concentration. Two consecutive ranges are allowed when one cannot contain the full range. Employers do not calculate or replace this value. They must match a new SDS to the product identifier and manufacturer. Helios Comply can retrieve documents, but a person must examine the match.
Section 9: Physical and chemical properties
The final rule changes the Section 9 property list. It separates physical state and color, reorganizes odor threshold and evaporation rate, specifies kinematic viscosity, and adds particle characteristics for solids. Employers do not create missing test data or edit the supplier’s list. They compare revisions for changes that affect storage, handling, controls, or emergencies. A blank field does not prove that no hazard exists.
Section 11: Toxicological information
Section 11 now calls for relevant, readily available information about interactive effects. If specific data are unavailable, the preparer must identify alternative information and its method. An employer examines new routes, symptoms, effects, or measures against Sections 2 and 8. It must ask the supplier about unexplained conflicts instead of changing the SDS.
OSHA does not require annual revision. The update duty starts when the preparer learns significant new hazard or protective-measure information. An older revision date alone does not make an SDS expired.
Which compliance dates apply now?
OSHA extended every transition deadline by four months on January 15, 2026. The current dates are:
- May 19, 2026: Suppliers comply with modified provisions for substances. This deadline has passed.
- November 20, 2026: Employers make necessary label, program, and training updates for substances.
- November 19, 2027: Suppliers comply with modified provisions for mixtures.
- May 19, 2028: Employers make necessary workplace updates for mixtures.
Covered parties can use the prior standard, the updated standard, or both during a transition period. State-plan workplaces can face state rules that are at least as effective as the federal rule. Examine each state’s requirements. The passed supplier deadline does not prove that every employer received every substance revision.
What must an employer that uses chemicals do?
Start with the chemical inventory. Suppliers classify products and prepare labels and SDSs. Employers maintain the written program, workplace labels, employee access, and training. Use this dated process:
- Now: List each hazardous chemical with a product identifier that references its SDS. Add the manufacturer and locations as tracking fields.
- Now: Separate substances from mixtures and get the current supplier SDS.
- Now: Match its product identifier and manufacturer to the container label.
- Before November 20, 2026: Compare revised substance hazards, statements, pictograms, and protective measures.
- Before November 20, 2026: Update affected workplace labels, the written program, and training.
- Through November 19, 2027: Collect revised mixture SDSs as suppliers complete their work.
- Before May 19, 2028: Complete necessary workplace updates for mixtures.
- Every work shift: Keep each required SDS immediately available and provide backup access for likely system failures.
For each revision, record the supplier, product identifier, date, locations, affected tasks, and resulting action. Compare Sections 2, 3, 9, and 11 with the prior version. If an SDS is missing, document the request and keep the current copy available. Do not invent a classification. Helios Comply supports digitization, retrieval, status tracking, and barcode or image intake. A person must still match each SDS to its product and manufacturer.
OSHA permits electronic storage when employees have immediate SDS access during each work shift. Employers need backup access for likely system failures or temporary servicing. OSHA treats catastrophic emergencies differently. A dead device or manager-only password is a barrier. The guide to OSHA SDS access rules gives practical tests. Helios Comply supports QR, mobile, and offline access. Employers must test devices, credentials, and outage methods at each location.
How do labels and training change?
Suppliers have limited options for containers of 100 milliliters or less. They can reduce information only when pull-out labels, fold-back labels, or tags are not feasible. The label needs the product identifier, pictograms, signal word, and manufacturer’s name and telephone number. It must direct users to the outer package for full information. A container of 3 milliliters or less can carry only the product identifier when another label interferes with use.
The immediate outer package must carry the full shipped-container label and tell users to keep small containers inside when not in use. These options do not remove the employer’s duty. Secondary containers still need workplace-label information unless the immediate-use exception applies. See the written HazCom program and GHS labeling guide. Helios Comply can generate labels from controlled records, but employers must select the correct record and keep labels legible.
OSHA requires more training when a newly identified covered hazard applies. The update alone does not require a full training event. Instruction must address the new hazard and workplace protections. Helios Comply can track assignments, completion, and certificates. Employers decide who needs workplace-specific instruction.
How Helios Comply helps
Helios Comply keeps a central chemical and SDS library with multi-location controls, expiry/status tracking, and audit-ready reports. Teams can digitize files, retrieve SDSs, use barcode or image intake, generate labels, and track training. Employees can use QR, mobile, or offline access. These tools do not replace employer judgment or responsibility.
Start Free Trial to organize the transition, or call (855) 920-5202 for hands-on setup.
Frequently asked questions
Do employers need to replace every SDS immediately?
No. Employers must maintain received SDSs and request missing documents. Obey the current supplier and workplace deadlines.
Did OSHA replace the 16-section SDS format?
No. The order remains. The rule revises information in Sections 2, 3, 9, and 11.
Does the rule require annual HazCom training?
No federal annual schedule appears in 29 CFR 1910.1200. Employers train at initial assignment and for newly introduced covered hazards. State plans can add duties.
Does software make a company HazCom compliant?
No. Software can organize records and access. The employer must maintain a workplace-specific program and meet the rules.
Sources
- OSHA, 29 CFR 1910.1200, Hazard Communication
- OSHA, Final Rule to Amend the Hazard Communication Standard
- OSHA, 2024 Hazard Communication Standard Final Rule
- OSHA, Questions and Answers for the 2024 HCS Update
- Federal Register, 2026 Extension of Compliance Dates
- OSHA, Electronic Access and Backup for Likely System Failures
- OSHA, Electronic SDS Access During Emergencies