Updated November 7, 2026. This is general information, not legal advice. Check the standard and your state's rules for your own workplace.
If you use chemicals at work (cleaning products, solvents, adhesives, fuels, paints), OSHA's Hazard Communication Standard (HazCom) applies to you. The revised standard has a date that falls on November 20, 2026. Most of what is written about it comes from law firms and SDS vendors, and it is easy to come away thinking every label and every course must be redone. The rule text says something narrower. This post walks through what it says, then gives a short plan a small business can finish before the date.
The short version
- The date: November 20, 2026, for employers whose chemicals are substances. For mixtures, the employer date is May 19, 2028. (29 CFR 1910.1200(j)(2)(ii) and (j)(3)(ii), as amended by Federal Register notice 2026-00653.)
- What you update: three things, and only for newly identified hazards: (1) any alternative workplace labeling you use under (f)(6), (2) your written hazard communication program, and (3) employee training under (h)(3).
- What triggers the work: new hazard information that arrives from your suppliers. The suppliers' own date for substances was May 19, 2026, so updated labels and safety data sheets (SDSs) are already reaching you.
- Is training yearly? No fixed interval appears in the standard. Training is required at initial assignment and when a new chemical hazard the employees have not been trained on enters their work area.
- Records: the standard does not prescribe a training sign-in sheet, but a dated attendance record is how you show training happened.
- Extension? As of November 7, 2026 we found no further extension on OSHA's pages or in the Federal Register. Check again before you rely on this date.
What actually has to change by November 20
| Substances | Mixtures | |
|---|---|---|
| Suppliers (manufacturers, importers, distributors) | May 19, 2026 | November 19, 2027 |
| Employers: update alternative workplace labels, the written program, and training for newly identified hazards | November 20, 2026 | May 19, 2028 |
The Federal Register notice states the employer duty in three parts: update any alternative workplace labeling used under paragraph (f)(6), update the hazard communication program, and provide any additional employee training under (h)(3), with training tied to "newly identified" physical, health or other hazards. The same notice says the earlier version of the standard can still be followed until those dates (paragraph (j)(4)).
So the job is not "redo everything." It is: find out what changed for the chemicals you actually have, and update the three places where that shows up.
Not sure whether a product counts as a substance or a mixture? Look at the product's SDS or ask the supplier. Many products on a small-business shelf are mixtures, which is why the 2028 date matters. Do not assume, though: a pure single chemical (some solvents, for example) is a substance.
Step 1: Walk your chemicals and check the SDSs
Your written program must include a list of the hazardous chemicals known to be present, using a product identifier that matches the one on the SDS (1910.1200(e)(1)). OSHA's inspection directive says the inventory must include all chemicals present, even if they are stored and not in use (CPL 02-02-079, section X.E.4.a).
Walk every place chemicals live: the shop, the janitor closet, the truck, the back room, the roof unit. For each product, record:
- the product name exactly as it reads on the label
- where it is stored
- whether an SDS is on hand and whether it is the current one from the supplier
- a photo of the label, so you can compare it with the SDS later
- anything that looks new: a new pictogram, a new hazard statement, a replaced SDS
Products you have not walked yet are the useful list. Keep it visible until it is empty.
Step 2: Check your workplace labels
Containers that arrive from the supplier carry the supplier's label. The labels you make are the ones to review: secondary containers (spray bottles, transfer jugs) and any system you use in place of the full shipped-container label.
Under (f)(6), a workplace label can carry the full shipped-container label information, or a product identifier plus words, pictures or symbols that give at least general hazard information. If you use the second approach, compare it with the updated SDS. If a hazard was newly identified, your label needs to reflect it. If nothing changed for a product, there is nothing to relabel.
Step 3: Review your written program
You are required to have a written program at each workplace (1910.1200(e)(1)). The November 20 duty is to update it for the new hazard information. In practice that means:
- the chemical list from Step 1 matches what is really on site
- the labeling section describes the labels you actually use
- the training section describes what you will do for the new hazards
- the program says where employees can read it
Tell employees where the program is kept. The standard lists the location and availability of the written program among the things employees must be informed of ((h)(2)).
Step 4: Training
Training has to cover, at least, the items in (h)(3):
- methods and observations used to detect the presence or release of a hazardous chemical in the work area
- the physical and health hazards of the chemicals in the work area, including hazards not otherwise classified
- what employees can do to protect themselves, including your procedures, emergency procedures and PPE
- details of your program: how to read the labels on shipped containers, your workplace labeling system, and the SDS, including how to get and use hazard information
For November 20, the point is additional training on newly identified hazards, not a full repeat of everyone's HazCom course. A short briefing for the people who work with the affected products is the usual size of the job. Use plain language: OSHA's inspection directive expects the program to say how you train employees in a language and at a literacy level they understand (CPL 02-02-079, X.E.4.g). If part of your crew reads Spanish, brief them in Spanish.
The standard sets no length for training.
Is HazCom training required every year?
Not by the text of the standard. Paragraph (h)(1) requires effective information and training at the time of initial assignment, and whenever a new chemical hazard the employees have not previously been trained about is introduced into their work area. There is no annual interval written there.
Many employers still run a yearly refresher because it is easy to schedule and easy to prove. That is a practice choice. If you do it, call it that.
How to keep a record of who attended
The standard text we read does not prescribe a training record. Keeping one is still the simplest way to show, later, that the briefing happened. A useful record has:
- the date and who ran it
- what was covered (list the chemicals or the hazard that changed)
- who attended, with a typed name for each person
- anything that was handed out, such as the updated SDS
A paper sheet works. A QR code at each chemical storage area works better for the walk in Step 1: whoever scans it sees that area's checklist already open, can log what they checked and attach a photo of the label, and you can see which areas have not been done. It keeps the walk on a phone, with a history behind it, and no login is needed to fill it in. It helps you keep records. It does not make a workplace compliant by itself, and it does not replace the walk or the training.
A plan for the last two weeks before November 20
| Dates | Do this |
|---|---|
| Nov 9 | Pick the person responsible. List every storage area. Pull the supplier SDS file. |
| Nov 10-12 | Walk the areas. Record each product, its label and its SDS. Note anything new. |
| Nov 13 | Contact suppliers for any missing or outdated SDS. Check your own secondary-container labels. |
| Nov 16-17 | Update the written program and the chemical list. |
| Nov 18-19 | Brief the people who use the affected products. Record attendance. |
| Nov 20 | File the program, the list and the attendance record where you can find them. |
Short on time? The walk and the list come first.
FAQ
What do I have to update by November 20, 2026? Alternative workplace labeling, the written hazard communication program, and employee training, for newly identified hazards in substances. Mixtures follow on May 19, 2028.
Do I have to rewrite my whole program? The duty is to update it. If your list of chemicals, labels and training description are already accurate, the update may be small. Check them against the new SDS information first.
Do all employees have to be retrained? Not by the text we read. Additional training is tied to newly identified hazards in the work area. The people who work with those chemicals are the ones to brief.
Is a HazCom sign-in sheet required? The standard does not prescribe one. A dated attendance record is how you show the training took place.
Does my state have different dates? Possibly. If you are in a state with its own OSHA-approved plan, check its dates and rules on OSHA's State Plans page.
Is there a federal penalty for missing the date? This post does not quote penalty amounts. See OSHA's penalties page for current figures.
Where do I find the exact rule? The links below.
Sources
- Federal Register 2026-00653, Hazard Communication Standard, January 15, 2026
- 29 CFR 1910.1200 on eCFR
- OSHA regulatory text with January 2026 changes (redline)
- OSHA inspection directive CPL 02-02-079
- OSHA Hazard Communication page
A checklist you can start from
If you want the walk and the attendance record on a phone, start a free workspace and build a chemical storage check with one QR code per area. It is free to start with and editable for your own site. It helps you keep records; it does not guarantee compliance with any regulation.
What this post does and does not do
It summarizes the employer dates and duties in the revised standard as published on January 15, 2026. It does not replace the standard, your state's rules, or advice from a safety professional. A checklist or QR code does not make a workplace compliant on its own.