Overview 

On January 15, 2026, the United States Federal Register published an important update: the Occupational Safety and Health Administration (OSHA) is extending the compliance dates in its Hazard Communication Standard (HazCom), published in the Federal Register on May 20, 2024 (89 FR 44144), by four months.

Background of the HCS-2024 Revision

On May 20, 2024, OSHA officially published the revised Hazard Communication Standard (HCS-2024; 29 CFR 1910.1200) in the Federal Register, aligning it comprehensively with the United Nations’ Globally Harmonized System of Classification and Labelling of Chemicals (UN GHS) Seventh Revised Edition and certain provisions from the Eighth Revised Edition. This revision replaces the HCS-2012, which was issued on March 26, 2012.

HCS-2024 became effective on July 19, 2024, and to facilitate an orderly transition for companies, OSHA established a phased compliance timeline with the following original schedule:

• Substances: Manufacturers, importers, and distributors, evaluating substances shall be in compliance with all modified provisions of this section no later than January 19, 2026. All employers shall, as necessary, update any alternative workplace labeling, update the hazard communication program, and provide any additional employee training for newly identified physical hazard, or health hazards or other hazards no later than July 20, 2026.

• Mixtures: Chemical manufacturers, importers, and distributors evaluating mixtures shall be in compliance with all modified provisions of this section no later than July 19, 2027. All employers shall, as necessary, update any alternative workplace labeling, update the hazard communication program, and provide any additional employee training for newly identified physical hazards, health hazards, or other hazards no later than January 19, 2028.

Extension of Compliance Deadlines for HazCom Standard

The initial compliance deadline in section 1910.1200(j)(2)(i) of January 19, 2026, for manufacturers, importers, and distributors evaluating substances, is imminent. Members of the regulated community have asked for additional guidance to comply with the updated HCS.

OSHA has determined it is necessary to extend the compliance date by four months to allow time for the agency to publish the necessary guidance materials and for the regulated community to review those materials before the revised provisions take effect:

• Substances: The compliance date is extended from January 19, 2026, until May 19, 2026; and from July 20, 2026 to November 20, 2026.

• Mixtures: The compliance date is extended from July 19, 2027 to November 19, 2027; and from January 19, 2028 to May 19, 2028.

Compliance Recommendations from REACH24H

In establishing the effective date of this action, OSHA invokes the good cause exception in 5 U.S.C. 553, which allows the action to be immediately effective for ‘‘good cause’’ rather than subject to the requirement that rules become effective no earlier than 30 days after publication.

During the current transition period, manufacturers, importers, distributors, and employers may choose any of the following compliance options based on their circumstances:

• Comply with the previous standards HCS-2012 (77 FR 17574);

• Comply with the revised standard HCS-2024 (89 FR 44144)

• Or a combination of both.

Although OSHA has not yet finalize the key guidance for the updated HCS, the key differences between HCS-2024 and HCS-2012 have already been clearly outlined. REACH24H recommends that relevant companies begin Compliance Preparation Work in advance, focusing on the following five areas:

1. Revisions to Standards for Specific Health and Physical Hazard Classifications

• Updates to the Classification System (including Flammable Gas, Aerosol, and Desensitized Explosive);

• Modifications to standards and Testing Methods (including Flammable Liquid, Skin Corrosion/Irritation, Serious Eye Damage/Eye Irritation, Carcinogenicity, Reproductive Toxicity, etc.).

2. Updates to Labeling Requirements

• Revisions to Precautionary Statements;

• Requirements for Small Container Labeling;

• Provisions for Hazards Not Otherwise Classified (HNOC);

• Requirements for Relabeling, etc.

3. Revisions to SDS Contents

• Requirements for Domestic Supplier Information;

• Requirements for Additives and sufficient Unique Identifiers;

• Requirements for Physical and Chemical Properties, etc.

4. New Provisions for CBI Concentration or Concentration Range

5. Additional Revisions

• The Scope of Hazard Classification;

• Requirements for Bulk Transport, etc.

For further inquiries or support regarding this action or assistance in implementing related compliance requirements, please contact REACH24H for professional support.

Additionally, REACH24H offers professional SDS and Label preparation and update services in compliance with U.S. HCS requirements. Please feel free to contact us if needed.