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OSHA Hazard Communication (HazCom) Compliance: An Employer's Guide

What employers must do to comply with OSHA's Hazard Communication Standard as it aligns to GHS Revision 7 — written program, labels, SDSs, and training.

Reviewed against coverage through Aug 18, 2026
Standard
29 CFR 1910.1200
Aligns to
GHS Revision 7 (2024 final rule)
Training timing
Before assignment & when new hazards appear

OSHA's Hazard Communication Standard (29 CFR 1910.1200) requires employers to identify hazardous chemicals in the workplace and inform and train workers about them. In 2024, OSHA finalized a rule aligning HazCom with the seventh revision of the UN Globally Harmonized System (GHS Revision 7), updating requirements for labels, safety data sheets (SDSs), and training.

Chemical manufacturers, importers, and distributors face earlier compliance dates; employers must update workplace labeling, their written hazard communication program, and worker training by the later 2026 compliance date in the final rule.

Regardless of the revision cycle, the core duties stay constant: a written HazCom program, a current chemical inventory, accessible SDSs for every hazardous chemical, properly labeled containers, and training delivered before exposure.

OSHA compliance checklist

  • Maintain a written HazCom program — Keep a current written program describing how you handle labeling, SDS access, and training.
  • Update your chemical inventory and SDS library — Ensure an SDS is on file and readily accessible for every hazardous chemical in use.
  • Refresh labels to GHS Revision 7 — Update workplace and secondary-container labels with current pictograms, signal words, and hazard statements.
  • Retrain employees — Train workers on the updated label elements and SDS format before the compliance deadline.
  • Document everything — Keep dated training records and your written program ready to produce during an inspection.

A starting point, not legal advice — verify against the primary sources cited below and current rules for your jurisdiction.

Key deadlines

Latest OSHA coverage

Frequently Asked Questions

Employers must comply with OSHA's revised Hazard Communication Standard (29 CFR 1910.1200) by November 20, 2026, for chemical substances. This includes updating workplace labels, safety data sheets, written HazCom programs, and completing employee retraining.

The 2024 final rule aligns OSHA's HazCom standard with GHS Revision 7, adding new hazard classes like desensitized explosives and chemicals under pressure, updating label elements and SDS requirements, and introducing new trade secret concentration range rules.

Yes. OSHA requires employers to retrain all affected employees on new hazard classifications, updated label elements, revised SDS formats, and any changes to safe handling procedures before the November 20, 2026 deadline.

In 2026, OSHA penalties for serious violations are up to $16,550 per violation. Willful or repeat violations can reach $165,514 per violation. Hazard communication is consistently among OSHA's most-cited standards.

OSHA provides guidance materials, the full regulatory text, and compliance resources at osha.gov/hazcom. The final rule was published in the Federal Register on May 20, 2024, and OSHA's enforcement directive CPL 02-02-079 details inspection procedures.

OSHA proposed $794,456 in penalties against Woodland Pulp LLC after a January 2026 hydrogen sulfide gas release killed two workers and exposed ten others. Investigators found the company exposed workers to deadly gas levels without proper alarms or breathing devices, let wood pulp accumulate in storage areas, and had a history of prior chemical safety citations at the same facility. The company contested the citations in August 2026.

Under OSHA's general industry standard (29 CFR 1910.1000, Table Z-2), the ceiling limit for hydrogen sulfide is 20 ppm, with a peak of 50 ppm for no more than 10 minutes once per shift. NIOSH recommends a 10-minute ceiling of 10 ppm and treats 100 ppm as immediately dangerous to life and health (IDLH); ACGIH's TLV is 1 ppm as an 8-hour average with a 5 ppm short-term limit.

A willful violation occurs when an employer knowingly fails to comply with OSHA requirements or acts with plain indifference to employee safety. In 2026, the maximum penalty for a willful violation is $165,514 per violation, while serious violations carry a maximum of $16,550 each.

Primary sources

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