In a Federal Register notice dated January 15, 2026, OSHA announced that some of the compliance dates for the Hazard Communication Standard changes that were published on May 20, 2024 will be extended. OSHA has indicated that it has been working to finalize key guidance but was unable to finish the guidance in time for affected entities to benefit from it by the original compliance dates.
Compliance dates are extended as follows in 1910.1200 paragraphs (j)(2) and (3):
(j)(2)
(i) Manufacturers, importers, and distributors, evaluating substances shall be in compliance with all modified provisions of this section no later than May 19, 2026.
(ii) For substances, all employers shall, as necessary, update any alternative workplace labeling used under paragraph (f)(6) of this section, update the hazard communication program required by paragraph (h)(1) of this section, and provide any additional employee training in accordance with paragraph (h)(3) of this section for newly identified physical hazard, or health hazards or other hazards covered under this section no later than November 20, 2026.
(j)(3)
(i) Chemical manufacturers, importers, and distributors evaluating mixtures shall be in compliance with all modified provisions of this section no later than November 19, 2027.
(ii) For mixtures, all employers shall, as necessary, update any alternative workplace labeling used under paragraph (f)(6) of this section, update the hazard communication program required by paragraph (h)(1) of this section, and provide any additional employee training in accordance with paragraph (h)(3) of this section for newly identified physical hazards, health hazards, or other hazards covered under this section no later than May 19, 2028.
So, for employers, the extension affects updating alternative workplace labeling (if applicable) for substances and mixtures and training for newly identified hazards. Alternative workplace labeling is only required if you take a product out of its primary, labeled container and put it into a secondary, unlabeled container.
Eagle Associates has provided a system for alternative workplace labeling for subscribers of the Custom Safety Program. This can be found in the “Hazard Communication” section of the “Safety Archive” page in the Member Services area of the website. Navigate there by logging in to Member Services and scrolling to the end of the Custom Safety Program main page. If you need assistance, call or email our office at (800) 777-2337, info@eagleassociates.net. You may need to provide additional employee training for newly identified hazards by November 20, 2026 for substances and by May 19, 2028 for mixtures, as identified in newly updated Safety Data Sheets that will be provided by manufacturers and suppliers on or before their new deadlines.
Please note that subscribers to Eagle Associates Custom Safety Program have already received policy updates, and updated training materials. Subscribers to the American Practice Advisor® and the e-Compliance Training Program have also received updated training materials.
