How the new hazard communication standards are meant to be applied

Last updated 2026-07-09

What is the new hazard communication standard and what changed?

OSHA published the final rule updating its Hazard Communication Standard on May 20, 2024, with an effective date of July 19, 2024 ^[1]. The rule is codified at 29 CFR 1910.1200 and reaches general industry, construction, maritime, and agriculture through their respective cross-references.

The short version: the U.S. was running on GHS Revision 3 since 2012. The world moved on. This update brings OSHA up to the United Nations Globally Harmonized System of Classification and Labelling of Chemicals, Revision 7 (GHS Rev. 7), closing more than a decade of drift between U.S. requirements and the system most trading partners and multinational companies already follow ^[1].

Here is what actually changed in practice:

• New hazard classes. OSHA added three hazard categories that were missing from GHS Rev. 3: desensitized explosives, non-flammable aerosols, and chemicals under pressure. Flammable aerosols gained a third category. Several health hazard categories, including skin corrosion/irritation and serious eye damage, got clarified criteria ^[1].
• Revised SDS and label content. Some signal words, hazard statements, and precautionary statements changed to match GHS Rev. 7 language. Manufacturers and importers will need to update Safety Data Sheets and labels accordingly.
• Small container labeling alternatives. The final rule expands options for labeling very small containers (think a 1 mL vial) where fitting full label text is physically impossible. Employers get more flexibility on pull-out labels, tags, and fold-back labels ^[1].
• Bulk shipment labeling. Clarified requirements for labeling chemicals shipped in bulk, matching Department of Transportation practices more closely.
• Workplace labeling. The rule tightens language around what employers who transfer chemicals into secondary containers must put on those containers.

The hazard communication standard has always been one of OSHA's most-cited rules. In fiscal year 2023, it ranked second on OSHA's top-10 citation list, with over 2,600 violations ^[2]. The 2024 update does not reduce that enforcement pressure. It moves the target.

When do the new HazCom compliance deadlines actually kick in?

OSHA phased the deadlines because different parties in the supply chain need different amounts of time. Here is the schedule from the final rule ^[1]:

Who	Obligation	Deadline
Chemical manufacturers, importers, distributors	Comply with all revised classification, SDS, and labeling requirements	July 19, 2026
Distributors	May ship products labeled under the old standard (GHS Rev. 3)	Until January 19, 2028
Employers (downstream users)	Update written HazCom programs; retrain workers on new label elements and SDS sections	January 19, 2028
All covered employers	Full compliance with the revised standard	January 19, 2028

The practical read: if you are a downstream employer (a manufacturer that uses chemicals but does not sell them, a construction contractor, a shop, a lab), your hard deadline is January 19, 2028. That sounds distant. But your chemical suppliers start shipping updated SDSs and labels as early as July 2026. If your workers receive a container with a GHS Rev. 7 label and your training still references old pictograms, you have a gap. Train on the new standard before your suppliers flip, not after.

One thing worth knowing: OSHA stated in the preamble to the final rule that employers should not wait until 2028 to act. Inspectors can and do evaluate whether a written program matches the chemicals actually present in the workplace. If your SDS files contain updated Rev. 7 sheets but your written program still describes the old classification structure, that is a real citation risk starting now.

Which employers does the HazCom standard apply to?

The standard covers any employer where workers may be exposed to hazardous chemicals under normal working conditions or in a foreseeable emergency ^[3]. That is a broad net.

It explicitly covers general industry (29 CFR 1910.1200), construction (29 CFR 1926.59), maritime (29 CFR 1915.99 and related subparts), and agriculture (29 CFR 1928.21). State-plan states must adopt standards at least as effective as the federal rule, and most adopt it word for word ^[4].

There are narrow exemptions: hazardous waste operations regulated under RCRA, tobacco products, wood products in their natural state, consumer products used the same way and for the same duration as a normal consumer would use them, drugs in final packaged form for direct administration, and a few others. For most small businesses, those exemptions do not matter. If you have cleaning chemicals, lubricants, solvents, paints, fuels, welding gases, or adhesives on site, you are covered.

Size does not exempt you. A five-person auto body shop has the same HazCom obligations as a 500-person chemical plant. The scale of the written program may look different. The core requirements are identical.

What must a written hazard communication program include under the new standard?

The written program requirement lives at 29 CFR 1910.1200(e). The rule says employers must develop, implement, and maintain a written hazard communication program that covers, at minimum ^[3]:

1. Labels and other forms of warning 2. Safety Data Sheets 3. Employee information and training 4. A list of the hazardous chemicals present in the workplace (by product name or chemical identity, matching the SDSs) 5. Methods for informing employees of hazards of non-routine tasks 6. Methods for informing contractors' employees about hazards they may encounter

The 2024 update does not tear up this list. What changes is the content the program must address. Your program now needs to describe how workers will be informed of the new hazard classes (desensitized explosives, non-flammable aerosols, chemicals under pressure) and the updated label elements for any chemicals that fall into revised or new classifications.

A few practical things the written program must reflect:

The chemical inventory. This list is your foundation. It does not need to be elaborate, but it must exist, stay current, and match the SDSs you have on file. OSHA inspectors routinely ask for the inventory on the first day of an inspection.

SDS access procedures. The program must explain how workers reach SDSs on every shift, including when the primary system (electronic or binder) is down. Electronic-only SDS systems are allowed, but you must document a backup plan ^[3].

Labeling system for secondary containers. If workers transfer chemicals from original containers into smaller unlabeled ones, your program must describe what information goes on those containers and who is responsible for putting it there.

If you want a faster starting point, SafetyFolio's safety program generator builds a HazCom-compliant written program in about 15 minutes, tailored to your industry and the chemicals you actually use.

One thing the rule does not require: a PhD in chemistry. OSHA's intent has always been practical communication, not scientific perfection. Your written program can say "we use commercial cleaning products; we keep the manufacturer's SDS for each product and train workers to read the signal word, hazard statements, and first aid section before using any new product." That is compliant. It is not fancy. It works.

How do GHS labels work under the revised standard?

GHS labels have six required elements under 29 CFR 1910.1200(f): product identifier, supplier information, signal word, hazard statement(s), precautionary statement(s), and pictogram(s) ^[3]. The 2024 update revised specific hazard and precautionary statement language for some categories to match GHS Rev. 7, but the six-element structure stays the same.

Here is a quick map of the nine GHS pictograms and what they mean ^[9]:

Pictogram	Hazard type
Flame	Flammables, self-reactives, pyrophorics, self-heating, emits flammable gas, organic peroxides
Flame over circle	Oxidizers
Exploding bomb	Explosives, self-reactives, organic peroxides
Skull and crossbones	Acute toxicity (fatal or toxic)
Exclamation mark	Irritants, skin sensitizers, acute toxicity (harmful), narcotic effects, respiratory tract irritation
Health hazard	Carcinogens, respiratory sensitizers, reproductive toxins, target organ toxins, mutagens
Corrosion	Skin/eye corrosion, metals corrosion
Gas cylinder	Gases under pressure
Environment (optional in U.S.)	Aquatic toxicity

The signal word is either "Danger" (more severe) or "Warning" (less severe). One label gets one signal word. If a chemical has both Danger and Warning hazards, only "Danger" appears ^[9].

For the new hazard classes added in 2024, desensitized explosives and chemicals under pressure each have defined pictogram and signal word requirements. Non-flammable aerosols (Category 3) uses no pictogram but requires the "Warning" signal word and a specific hazard statement ^[1].

Workplace (secondary container) labels do not need to reproduce the full GHS label format. They need the product identifier and general hazard information (words, pictures, or symbols) sufficient to warn workers. Your written program must describe the system you use.

What are Safety Data Sheets and how do the 16 sections apply?

Safety Data Sheets (SDSs, formerly called MSDSs) follow a 16-section format under Appendix D to 29 CFR 1910.1200 ^[10]. That structure did not change in 2024. What changed is some of the content required within sections for newly classified or reclassified chemicals.

The 16 sections are:

1. Identification 2. Hazard(s) identification 3. Composition / information on ingredients 4. First-aid measures 5. Fire-fighting measures 6. Accidental release measures 7. Handling and storage 8. Exposure controls / personal protective equipment 9. Physical and chemical properties 10. Stability and reactivity 11. Toxicological information 12. Ecological information (not enforced by OSHA, but required content) 13. Disposal considerations 14. Transport information 15. Regulatory information 16. Other information

For employers, sections 2, 4, 8, and 14 do most of the daily work. Section 2 tells you the hazard classification and label elements. Section 4 gives first aid. Section 8 lists exposure limits (PELs, TLVs, RELs) and required PPE. Section 14 flags DOT shipping requirements.

For a real-world example of how an SDS is structured for a common chemical, the hcl safety data sheet walkthrough shows exactly what each section means in practice.

One thing that trips up small employers: SDSs must be readily accessible to workers during their shift. "In the manager's locked office" does not qualify. A binder in the break room, an unlocked computer kiosk on the floor, or a QR code linking to a cloud folder all work, as long as workers know where they are and can reach them without asking permission.

What training do workers need under the updated HazCom standard?

The training requirement is at 29 CFR 1910.1200(h). Workers must be trained at the time of initial assignment and whenever a new physical or health hazard is introduced into their work area ^[3]. The 2024 rule does not change that trigger structure, but it adds training obligations tied to the new hazard classes and revised label elements.

At minimum, training must cover:

• The requirements of the HazCom standard itself and where workers can find the written program
• Operations in the work area where hazardous chemicals are present
• Where and how to reach SDSs
• How to read and understand labels, including the GHS pictograms, signal words, and hazard statements
• How to use SDS information to protect themselves (PPE selection, first aid, storage precautions)

For the 2024 update specifically, OSHA's preamble notes that employers must train workers on the new hazard classes before workers encounter chemicals classified under those new categories. If none of the chemicals in your workplace fall into desensitized explosives, non-flammable aerosols, or chemicals under pressure, your retraining burden is lighter. But you still need to verify that, not assume it.

How long does training need to be? The standard does not specify duration. What it specifies is that workers must actually understand the information. A 10-minute video that ends with a quiz workers can pass is more defensible than a 2-hour lecture nobody remembers. Document the training, the date, the topics covered, and the names of workers who attended. That documentation is what an OSHA inspector will ask to see.

For a broader look at how OSHA training requirements work across topics, the osha training guide covers the general structure. If your team is pursuing formal safety credentials, the osha 30 course covers HazCom principles as part of its hazard recognition modules.

How does the new HazCom standard handle multi-employer worksites?

Construction and other industries often have multiple employers sharing a worksite, each bringing their own chemicals. The HazCom standard's multi-employer provisions at 29 CFR 1910.1200(e)(2) require that employers who produce, use, or store hazardous chemicals in a way that exposes another employer's workers must give that employer SDS access and label information ^[3].

In practice, the controlling contractor (general contractor on a construction site, host employer at a facility) usually sets up a central SDS repository and coordinates HazCom information across subcontractors. Each subcontractor stays responsible for training their own workers.

The 2024 update does not change this framework. What it means practically is that as chemical suppliers update their SDSs and labels to GHS Rev. 7 format starting in mid-2026, those updated documents need to flow through to all workers on a site who use or work near those chemicals. A subcontractor cannot claim ignorance because the general contractor did not pass along an updated SDS. Responsibility is shared.

This also matters if you use contract workers or staffing agency employees. OSHA has long held that the host employer must provide HazCom information and, in many cases, training to temporary workers placed at their facility, even if the staffing agency is technically the employer of record.

What are the most common HazCom violations and how do you avoid them?

OSHA cited HazCom violations 2,632 times in fiscal year 2023, making it the second most frequently cited standard after fall protection ^[2]. The most common specific violations are predictable and mostly avoidable.

No written program or an outdated one. This is the single easiest citation to avoid. Write the program, keep it current, and make it reachable. If your program still says MSDS instead of SDS, update it before an inspector arrives.

Missing or incomplete SDSs. Every hazardous chemical on your inventory list needs a current SDS. "Current" means the version the manufacturer has published, reflecting their most recent classification. If you are getting new products and not pulling the SDSs, you will eventually have a gap.

Unlabeled secondary containers. Workers pour chemicals into spray bottles, buckets, and other containers all day. Those containers need labels. A roll of masking tape and a marker, combined with a clear protocol in your written program, solves this.

Inadequate training records. OSHA can accept a verbal assurance that training happened, but in practice, inspectors want paper (or digital) documentation. A sign-in sheet with the date, topics, and trainer name is the minimum.

Failure to train on new hazards. When you bring a new chemical into the workplace, that is a training trigger under the standard. Most citations in this category come from employers who trained workers once at hire and never again, even as the chemical inventory changed.

The lockout tagout standard has a similar written program structure and the same common failure modes. If you already manage one written program well, the discipline transfers straight to HazCom.

How do the new hazard classes (desensitized explosives, chemicals under pressure) actually affect most workplaces?

Honestly, most small businesses will never handle desensitized explosives. That category covers things like wetted or phlegmatized explosive substances used in specific industrial or demolition contexts. If you are not in mining, demolition, or specialty chemical manufacturing, this new class probably does not touch your chemical inventory at all.

Chemicals under pressure is a broader category. It covers aerosol and non-aerosol products that are liquid, paste, or powder held under pressure in a container. Certain industrial cleaners, lubricants, and process chemicals sold in pressurized containers may fall here. The label will tell you. If a product you currently use gets reclassified into this category by your supplier, you will see a new hazard statement and maybe a new precautionary statement on the updated SDS and label.

Non-flammable aerosols (Category 3) is the one most likely to show up in ordinary workplaces. Many spray lubricants, cleaners, and coating products are aerosols that are technically non-flammable. Under the old standard, those products may not have carried any aerosol hazard classification. Under the new standard, they carry a Category 3 aerosol classification, a "Warning" signal word, and a specific hazard statement. No pictogram is required for Category 3 ^[1].

The real implication: when your supplier updates labels starting in mid-2026, some products your workers touch every day will look different. They will carry new or additional hazard statements. If workers have not been told why the label changed, trust in the labeling system erodes. Brief, proactive communication before the changeover is worth more than a long retraining after workers have already learned to ignore a label they do not recognize.

How do you update your written HazCom program to comply with the 2024 rule?

Start with your chemical inventory. Pull up your current list and run each product against its current SDS. Note any chemicals that fall into the three new hazard categories or that have been reclassified under revised criteria. If a chemical has not been reclassified, your existing SDS and label information for that product stays valid until your supplier updates it.

Next, revise your written program to:

1. Reference the current standard language (29 CFR 1910.1200, effective July 19, 2024) rather than the 2012 version. 2. Add a description of the new hazard classes to your hazard explanation section, even if none of your current chemicals fall into them. This protects you if a new product shows up later. 3. Update your SDS access procedures if anything changed (new software, new storage location, new backup plan). 4. Update your training section to describe what workers will learn about revised label elements and the new classification categories. 5. Set a calendar reminder to re-verify SDSs against supplier updates starting in mid-2026, when manufacturers begin publishing revised documents.

The program does not need to be long. OSHA publishes a model written HazCom program on OSHA.gov that you can adapt ^[6]. It runs about three pages. A three-page program that is accurate and actually used beats a 30-page program that sits in a drawer.

If you want the program built around your specific industry, chemical types, and workforce size rather than a generic template, SafetyFolio's program generator walks you through each required element and produces a finished document you can put in place immediately.

How does HazCom enforcement work and what do OSHA inspections look for?

OSHA HazCom inspections usually happen two ways: as part of a programmed inspection (planned, targeting high-hazard industries) or as part of a complaint or incident investigation where chemical exposure is a factor.

Either way, inspectors typically ask for three things immediately: the written HazCom program, the chemical inventory, and SDS files. If all three are present, current, and reachable, you have passed the first filter. From there, they will look at container labels in the work area, interview workers about their training, and spot-check whether SDSs match the products present.

Penalties under the 2024 penalty structure run up to $16,550 per serious violation and up to $165,514 per willful or repeated violation (figures adjusted annually for inflation; current amounts are posted on OSHA.gov) ^[7]. HazCom violations are almost always characterized as serious because the hazard exposure is direct.

One thing inspectors look for that surprises some employers: consistency between the SDS on file and the actual product in use. If you switched product brands or formulations and did not update the SDS, that is a citation. Product names matter. "Generic degreaser" on a label with an SDS for a specific named product from a different manufacturer is a mismatch.

For a broader picture of how OSHA inspections work, including what triggers them and your rights during an inspection, the osha overview covers the process from start to finish.

Frequently asked questions

When did OSHA finalize the 2024 HazCom update?

OSHA published the final rule on May 20, 2024, with an effective date of July 19, 2024. The rule brings the U.S. Hazard Communication Standard up to GHS Revision 7. Downstream employers (most workplaces that use but do not manufacture chemicals) have until January 19, 2028 to fully comply, though manufacturers and importers face an earlier deadline of July 19, 2026.

Do small businesses have to comply with the new HazCom standard?

Yes. There is no small-business exemption in 29 CFR 1910.1200. Any employer whose workers may be exposed to hazardous chemicals under normal conditions or foreseeable emergencies must comply. A five-person shop using spray cleaners, lubricants, or solvents has the same core obligations as a large facility: written program, SDS access, labeled containers, and trained workers.

What are the three new hazard classes added in 2024?

OSHA added desensitized explosives, non-flammable aerosols (Category 3), and chemicals under pressure. Desensitized explosives apply mainly to specialty industrial or demolition contexts. Non-flammable aerosols affect common spray products. Chemicals under pressure covers pressurized non-aerosol containers. Flammable aerosols also gained a new Category 3 tier under the revised standard.

What is the difference between GHS Rev. 3 and GHS Rev. 7?

The U.S. HazCom standard adopted GHS Revision 3 in 2012. GHS Rev. 7 (published by the UN in 2017) added new hazard categories, refined classification criteria for existing categories, and updated hazard and precautionary statement language. The 2024 OSHA rule closes that 12-year gap. Most multinational chemical manufacturers had already adopted Rev. 7 for other markets, so the change harmonizes U.S. documentation with what suppliers were already producing globally.

Do I need to retrain all my workers immediately because of the 2024 update?

Not immediately, but do not wait until 2028 either. OSHA requires retraining when a new physical or health hazard is introduced into the work area. As your suppliers update labels and SDSs to Rev. 7 format starting around mid-2026, those updated documents may include new or changed hazard information that triggers retraining. Brief workers on what is changing and why before the label updates arrive, rather than after workers notice something looks different.

Can I store Safety Data Sheets electronically instead of keeping paper binders?

Yes. OSHA permits electronic SDS systems under 29 CFR 1910.1200. The requirements are that workers must be able to reach SDSs immediately during their shift without barriers (no locked rooms, no asking a supervisor for a password), the system must work on every shift, and you must document a backup plan for system outages. A printed backup binder or a designated backup computer are both acceptable backup methods.

What goes on a secondary container label when a worker transfers a chemical?

Under 29 CFR 1910.1200(f)(7), secondary containers must have the product identifier (name matching the SDS) and words, pictures, or symbols that convey the hazard. You do not need to reproduce the full GHS label. A label that says the product name plus something like "Flammable, Eye Irritant, See SDS" meets the standard. Your written HazCom program must describe the system you use, and whoever fills the container is responsible for labeling it.

Are contractors on my worksite covered by my HazCom program?

Partially. Under 29 CFR 1910.1200(e)(2), you must make SDSs available to contractor employees working in your facility and inform them of any hazardous chemicals they may encounter. The contractor is responsible for training their own workers. In practice, the host employer usually provides SDS access and location information; the contractor provides product-specific training for chemicals they bring to the site.

What is the penalty for a HazCom violation in 2024?

OSHA's current penalty for a serious violation is up to $16,550 per violation. Willful or repeated violations can reach $165,514 per violation. These amounts adjust annually for inflation under the Federal Civil Penalties Inflation Adjustment Act. HazCom violations are typically classified as serious because chemical exposure is a direct hazard. Multiple missing SDSs or unlabeled containers can result in multiple citations counted separately.

Does the HazCom standard require a specific format or length for the written program?

No specific format or length is required. The standard at 29 CFR 1910.1200(e) lists the required elements: labels, SDS access, training, chemical inventory, methods for non-routine task hazards, and contractor communication. OSHA publishes a model written program on OSHA.gov that you can adapt. A three-page document that accurately reflects your workplace is fully compliant. Length does not equal compliance; accuracy and implementation do.

How often does the chemical inventory need to be updated?

The standard does not specify an update frequency, but the inventory must reflect current conditions. In practice, update it whenever you bring in a new product, discontinue a product, or change suppliers for an existing product. Many employers do a formal review quarterly or annually. If an OSHA inspector finds a chemical in your facility that is not on the inventory, that is a citation. The inventory is only as good as the process you have for maintaining it.

Do I need to update my HazCom program if none of my chemicals fall into the new hazard classes?

You still need to update it to reference the current version of the standard (effective July 19, 2024), even if your specific chemical inventory does not include any newly classified products. Your program should also describe how you will handle new hazard classes if a new product is introduced. Beyond that, if your SDS files and labels are current and your training covers GHS label elements, the operational changes may be minimal until suppliers start issuing updated Rev. 7 documents.

Where can I find OSHA's model written HazCom program?

OSHA publishes a model hazard communication program on OSHA.gov under the HazCom resources page. Search for "OSHA Model Plans and Programs" or go directly to OSHA's HazCom standard page. The model is a fillable template covering the required program elements. It is a reasonable starting point, but it is generic. You will need to add your specific chemical inventory, your actual SDS access system, and your training approach to make it site-specific.

How does the HazCom standard interact with the DOT hazmat transportation rules?

They overlap but are separate. The DOT hazmat rules (49 CFR Parts 171-180) govern labeling and documentation during transport. OSHA's HazCom standard governs workplace communication once a shipment arrives. Section 14 of an SDS covers transport information and is meant to bridge the two systems. The 2024 HazCom update matched bulk shipment labeling more closely to DOT practices, reducing some conflicts between how a chemical is labeled in transit and how it is labeled in the workplace.

Sources

1. OSHA, Hazard Communication Standard Final Rule (89 FR 44144, May 20, 2024): Final rule published May 20, 2024, effective July 19, 2024, matching GHS Rev. 7; added desensitized explosives, non-flammable aerosols, chemicals under pressure; compliance deadlines July 2026 (manufacturers) and January 2028 (employers)
2. OSHA, Top 10 Most Frequently Cited Standards FY 2023: Hazard Communication was the second most cited OSHA standard in fiscal year 2023, with over 2,600 violations
3. OSHA, 29 CFR 1910.1200 Hazard Communication Standard (full text): Required elements of written HazCom program, training requirements at initial assignment and when new hazards introduced, SDS 16-section format, secondary container labeling, multi-employer provisions
4. OSHA, State Plans page: State-plan states must adopt standards at least as effective as federal OSHA standards
5. OSHA, Model Plans and Programs for the OSHA Bloodborne Pathogens and Hazard Communications Standards (OSHA 3186): OSHA publishes a model written hazard communication program employers can adapt
6. OSHA, Penalties page: Serious violation penalty up to $16,550; willful or repeated violation up to $165,514, adjusted annually for inflation
7. United Nations Economic Commission for Europe, Globally Harmonized System of Classification and Labelling of Chemicals (GHS), 7th Revised Edition: GHS Revision 7 published 2017; adds and revises hazard categories that OSHA's 2024 rule adopted
8. OSHA, HazCom Standard Appendix C: Allocation of Label Elements: Nine GHS pictograms, signal word allocation rules, one signal word per label when multiple hazards exist
9. OSHA, HazCom Standard Appendix D: Safety Data Sheets: 16-section SDS format requirements
10. Bureau of Labor Statistics, Survey of Occupational Injuries and Illnesses: Chemical exposure and contact with harmful substances account for a measurable share of nonfatal occupational injuries and illnesses annually
11. OSHA, Federal Civil Penalties Inflation Adjustment Act penalty adjustments: OSHA penalty amounts adjusted annually for inflation under the Federal Civil Penalties Inflation Adjustment Act