OSHA Hazard Communication Compliance Deadline Set for Nov. 20

A deadline for compliance with 2024 revisions to OSHA’s Hazard Communication Standard (HCS) is approaching for home builders and other downstream chemical users. Employers must:

• Comply with revised classifications or hazard information on labels for substances in their workplaces by Nov. 20, 2026.
• Comply with any new classifications and hazard information for mixtures in their workplaces by May 19, 2028.

OSHA’s standard requires all employers that manufacture, distribute, import, or use hazardous chemicals to implement documentary, training, and other hazard communication practices.

In 2024, OSHA updated the standard to conform with domestic interagency and international agreements. OSHA state plans are required to implement conforming updates. The 2024 HCS updates have a more limited effect on residential construction and other downstream users than did the HCS updates made in 2012.

The hazard communication standard is consistently among the OSHA standards most cited in construction industry violations.

Unlike the 2012 update, the 2024 update does not make universal changes to the information manufacturers provide to downstream users and therefore does not require comprehensive retraining. The 2024 update primarily affects residential construction employers and other downstream chemical users indirectly by:

• changing the factors that dictate how manufacturers and importers classify and categorize hazards; and
• creating new or expanded classes or categories for flammable gasses, certain materials with explosive potential, and aerosols.

The updates will change the Safety Data Sheet (SDS) content and other information that downstream users receive from chemical manufacturers and importers. Downstream users may already have noticed changes in the information they receive from suppliers.

To ensure compliance, residential construction employers should:

• Identify any materials they use that have been reclassified.
• Confirm that any revised SDSs are made available to employees.
• Make conforming revisions to their chemical inventories. 
• Make any other required changes to training for affected employees and written chemical hazard communication programs.

FAQs, a redline showing amendments to the regulatory text, and other guidance on the update is available on OSHA’s website.