01
The update in one table
OSHA published the final rule on May 20, 2024 (89 FR 44144), updating 29 CFR 1910.1200 primarily to Revision 7 of the UN's Globally Harmonized System. For an employer, the most useful sentence in the whole preamble is OSHA's own: the rule "does not change the fundamental structure of the HCS." The five employer duties — written program, an SDS for everything, real access, labels, training — are the same duties they were (covered in the requirements guide). What changed is mostly how manufacturers classify chemicals and write up the results.
The compliance calendar is phased, and on January 15, 2026 OSHA extended every date in it by four months (91 FR 1695). Articles written before then show deadlines that no longer apply. The dates in force (§1910.1200(j)):
| Date | Who | What must be done |
|---|---|---|
| May 19, 2026 | Manufacturers, importers, distributors | Substances classified, labeled, and documented to the updated rule. Passed. |
| Nov 20, 2026 | All employers | Workplace labeling, the written program, and training updated as necessary for substances. |
| Nov 19, 2027 | Manufacturers, importers, distributors | The same, for mixtures. |
| May 19, 2028 | All employers | Workplace updates, as necessary, for mixtures. |
Until those dates arrive, the rule lets manufacturers, distributors, and employers comply with the previous version of the standard, the updated one, or both (§1910.1200(j)(4)). That is why your library legitimately holds a mix of old-format and new-format sheets right now, and will until the mixture dates run out in 2028.
02
What the employer deadline actually says
The employer paragraph is one sentence. For substances, by November 20, 2026, all employers shall, "as necessary," do three things (§1910.1200(j)(2)(ii)): update any alternative workplace labeling used under §1910.1200(f)(6); update the hazard communication program; and provide additional employee training for newly identified hazards. The mixtures paragraph, due May 19, 2028, repeats the same three items (§1910.1200(j)(3)(ii)).
The words doing the work are "as necessary" and "newly identified." The trigger is a hazard that is new to your workplace because a manufacturer reclassified a chemical — not the date on the calendar. OSHA said so when it wrote the rule: because the update makes only limited changes to classification, the agency "does not anticipate that most employers will need to complete additional requirements," and it set the employer date six months after the manufacturer date for those that do (89 FR 44144, preamble discussion of paragraph (j)).
"Most employers" is not the same as "you," though, and a site that never checked has no way to show it's in the majority. The real work before November 20 is a review: find the sheets whose hazards changed, update labels, program, and training for those products, and keep a dated record that you looked.
03
What changed upstream that can reach your floor
A "newly identified hazard" reaches your site as a revised supplier SDS. These are the 2024 changes most likely to show up on one:
| Change | What you may see on a revised sheet |
|---|---|
| Non-flammable aerosols | The aerosols class grew from flammable-only to three categories, adding one for non-flammable aerosols (Appendix B.3.1). OSHA's preamble explains most such cans were previously classified as gases under pressure — so a spray can's sheet may swap that classification for an aerosol one, with the statement "Pressurized container: may burst if heated." OSHA also declined to allow the gas-cylinder pictogram on aerosol products, so that symbol may disappear from the label. |
| Chemicals under pressure | A new hazard class for liquids or solids (pastes, powders) pressurized with a gas at 200 kPa gauge or more at 20 °C, in receptacles other than aerosol dispensers (Appendix B.3.2). |
| Flammable gases 1A / 1B | Category 1 split into 1A and 1B, with pyrophoric and chemically unstable gases placed in 1A (Appendix B.2). |
| Desensitized explosives | A new hazard class for explosives treated to suppress their explosive properties (Appendix B.17). Rare outside specialized operations. |
| Reaction products | Classification must now expressly cover hazards from a change in physical form and from reaction products of known or reasonably anticipated uses (§1910.1200(d)(1)). Think two-part epoxies mixed at the bench. Reaction-product hazards belong in SDS Section 2 but need not appear on the shipped label (§1910.1200(f)(1)). |
| Document mechanics | Revised precautionary-statement wording (Appendix C), concentration ranges from a fixed list when a manufacturer withholds exact percentages as a trade secret (§1910.1200(i)(1)(iv)), and new small-container label options (§1910.1200(f)(12)). |
The deadline is triggered by newly identified hazards (§1910.1200(j)(2)(ii)), and the rule doesn't define the term further. A change that adds a hazard class or moves a product into a more severe category plainly counts. A reworded precautionary statement or a concentration range in Section 3 adds no hazard. Changes in between — a spray can moving from "gas under pressure" to "aerosol," a pictogram that dropped off — deserve a written judgment call rather than a shrug. And any workplace label carrying hazard information still follows the general six-month update rule for significant new hazard information (§1910.1200(f)(11)), deadline or no deadline.
04
How to tell whether your site is affected
A two-hour review settles it for most sites:
- Pull the candidates. Every SDS must carry its date of preparation or last revision in Section 16 (§1910.1200(g)(2)(xvi)). Any sheet revised since May 20, 2024 is a candidate; older ones can't reflect the update.
- Compare Section 2, old against new. Hazard classes and categories, signal word, pictograms. If the classification is the same, the product needs nothing under the deadline, whatever else changed on the sheet.
- Look hardest at pressurized products. At most sites that aren't chemical plants, spray cans and pressurized dispensers are the likeliest place a new classification shows up.
- Check two-part products. Epoxies, two-component coatings, anything mixed before use — look for reaction-product hazards newly described in Section 2.
- Request what hasn't come. Manufacturers and importers must send the updated sheet with the first shipment after an update and provide one on request (§1910.1200(g)(6)(i), (iv)); distributors must pass it along with the first shipment after an update (§1910.1200(g)(7)(i)), and wholesale distributors must provide sheets on request (§1910.1200(g)(7)(vi)). A product you buy rarely may not have shipped since its sheet changed — ask.
- Write down the result. Product, old versus new classification, action taken or "no change." That list is your evidence of the review.
05
Closing the three items
| Item | What "as necessary" means in practice |
|---|---|
| Workplace labels | The deadline paragraph names alternative workplace labeling under (f)(6) — NFPA diamonds, HMIS bars, in-house symbol systems. Re-rate or re-mark the reclassified products. Full-format workplace labels are covered anyway by the general update rule, which names employers too: labels are revised within six months of becoming aware of significant new hazard information (§1910.1200(f)(11)). The secondary container guide covers both formats. |
| Written program | Check the chemical inventory's product identifiers against the revised sheets — identifiers sometimes change on revision, and the list must use the name on the SDS (§1910.1200(e)(1)(i)). Update the labeling-system description if it lists hazard categories or symbols that changed. |
| Training | Training is owed when a chemical hazard employees haven't been trained on enters their work area (§1910.1200(h)(1)). The same paragraph lets training cover categories of hazards, so a crew already trained on pressurized-container hazards isn't facing a new hazard just because a can's classification moved. A genuinely new class for them — a pressurized paste, a reaction-product hazard at the mixing bench — gets a training session — and a written record of it, which the standard doesn't require but which is your only proof it happened. |
One quirk worth knowing if you read the regulation yourself: the deadline paragraph refers to the program "required by paragraph (h)(1)," although the written program itself is required by paragraph (e). The sensible reading is the written program, and that is how to treat it.
06
When the updated sheets haven't arrived
You can't train on a reclassification you've never been told about. The duty to produce updated sheets sits upstream, and the duty to get them to you is written into the standard (§1910.1200(g)(6)–(7)). Your part is to ask, and to be able to show that you asked: date, supplier, product, response.
Nothing in the rule excuses the deadline, but OSHA's enforcement has long turned on good faith you can document. Its 2015 HazCom inspection directive — now labeled an archive document — told compliance officers not to cite an employer for a missing SDS where the employer can show a good-faith effort to obtain it, giving "documented phone calls, email, letters" as examples. Dated requests are what good faith looks like on paper. An undocumented "we figured they'd send it" is not.
And November 20 is not the end of the story. Mixture sheets can keep arriving through November 19, 2027. Each one that brings a new hazard restarts the ordinary duties: training when a new hazard enters a work area (§1910.1200(h)(1)), labels within six months (§1910.1200(f)(11)). Build the Section 2 comparison into how revised sheets get filed, and the 2028 mixture date takes care of itself.
07
The November 20 checklist
Print this, work through it, and date each line:
- Candidate sheets pulled — everything revised since May 20, 2024.
- Section 2 compared — old versus new classification recorded for each candidate.
- Pressurized and two-part products checked — aerosols, pressurized dispensers, epoxies, and other mixed-before-use products.
- Missing revisions requested — dated requests on file for substances whose updated sheets haven't arrived.
- Alternative labels updated — NFPA, HMIS, or in-house ratings re-marked for every reclassified product.
- Full-format labels on the six-month clock — reprinted for products whose hazards changed.
- Inventory identifiers match the revised sheets — character for character.
- Training delivered for genuinely new hazards — with a record of who attended; not required by the standard, but it's your proof.
- Review record filed — the dated list, kept with the written program.
- Mixtures on the calendar — revised mixture sheets get the same Section 2 comparison as they arrive, through the May 19, 2028 employer date.
The review is mostly a library question: which sheets changed, and which of those changes are hazards. SDS HQ's library keeps every supplier sheet in one searchable place, with the pictograms and hazard codes read off each upload so a changed Section 2 is easy to see, and workplace labels print from the sheet on file. Replace the sheet, reprint the label, and the two agree.
NOTEThis guide is general information about the cited standards, not legal or professional advice for your facility. Regulatory text and agency enforcement practice control; confirm requirements against the standard and your competent person. Claims last reviewed October 6, 2026.