HazCom 2024 Compliance
OSHA Updated HazCom. Four Compliance Windows. Every Manufacturer Affected.
OSHA's HazCom 2024 revision is final — and it phases in through 2028 with four distinct compliance windows. SDSs need updates. Labels need updates. Written programs need updates. Employee training needs updates. iSi manages the whole program so your team doesn't have to.
What HazCom 2024 Actually Changed
OSHA's HazCom 2024 revision aligns the US standard more closely with the UN GHS Revision 7. The changes aren't cosmetic — they require actual SDS, label, and program updates across every manufacturing facility that handles regulated chemicals.
Updated Physical Hazard Classifications
New and revised classification criteria for certain physical hazards. Chemical manufacturers must re-evaluate their products under the updated criteria — and downstream users must verify their SDSs reflect the new classifications.
Revised SDS Requirements
Specific SDS sections — particularly hazard classification, health hazard details, and physical property information — now require updated formatting and content to match GHS Revision 7 standards. SDSs that were compliant under HazCom 2012 (GHS Rev. 3) may not meet the 2024 standard. Every SDS in your library needs a compliance check.
Label Element Updates
Signal words, hazard statements, and pictogram requirements updated for specific chemical classifications. Labels that passed inspection under the previous standard may now have gaps under HazCom 2024.
Four Compliance Windows Through 2028
OSHA extended all original deadlines by 4 months. Verify specific dates against the Federal Register notice — each window has a different audience and obligation set.
Note on compliance dates: The four windows above show the extended deadlines OSHA set in January 2026. If your facility is a chemical manufacturer/importer, your SDS and label deadline is May 19, 2026. If you're an employer using chemicals (downstream user), your program update and training deadline is November 20, 2026 for substances and May 19, 2028 for mixtures. iSi can clarify which timeline applies to your specific role and help you prepare ahead of deadline.
Each Window Is a Separate OSHA Enforcement Trigger
A common mistake: treating HazCom 2024 as one deadline rather than four. OSHA can cite a facility for missing any individual window — even if the facility is working toward full compliance. Missing Window 3 (written program and training updates) while still updating SDSs is a separate, citable violation.
The other dynamic: each compliance window is an outreach moment. Facilities that complete their Window 1–2 obligations before deadline and communicate that to employees and suppliers are demonstrating a functioning HazCom program — exactly what OSHA expects to see in an inspection.
Review My HazCom ProgramHazCom 2024 Questions
What changed in OSHA's HazCom 2024 rule?
OSHA's HazCom 2024 revision aligns the standard more closely with the UN GHS Revision 7. Key changes include new physical hazard classifications, revised SDS content requirements for certain chemical categories, updated label elements, and expanded coverage of some chemical mixtures. OSHA extended the original compliance deadlines by 4 months to give manufacturers additional transition time.
How many compliance windows are there and what are the obligations?
HazCom 2024 phases in through four windows. Window 1 requires chemical manufacturers and importers to update SDSs and labels by May 19, 2026. Window 2 requires distributors to ship only compliant products by November 19, 2027. Window 3 requires all employers to update their written HazCom programs and provide updated employee training by November 20, 2026. Window 4 is the final full-compliance deadline for employers on chemical mixtures by May 19, 2028. Contact iSi if you need clarity on which window applies to your facility's role in the supply chain.
Does HazCom 2024 affect every manufacturing facility?
Yes — any facility that handles chemicals subject to HazCom (essentially every manufacturing operation) must comply. Most manufacturers are downstream users and face mid-range deadlines. Core obligations for downstream users are: verify your SDS library is being updated by your chemical suppliers, update your written HazCom program to reference the 2024 standard, and provide updated employee training on new classification criteria and label elements.
We already have a HazCom program. Does it need updating?
Yes. Any written HazCom program that references "HazCom 2012" or "GHS Revision 3" needs to be updated to reference the 2024 standard. Your employee training must cover the new classification criteria and label elements. Your SDS library must be audited to confirm suppliers have provided updated 2024-compliant SDSs before the applicable window closes. A HazCom program audit by iSi takes 1–2 days and identifies exactly what needs updating.
HazCom Compliance Support by Market
Four Windows. Every Manufacturer Affected. Don't Miss One.
iSi reviews your current HazCom program against the 2024 standard, identifies what needs updating, and manages the SDS library, label review, and training updates.
Get a HazCom Program Review