On January 15, 2026, OSHA issued a final order extending the compliance dates in its Hazard Communication (HazCom) Standard (29 CFR 1910.1200(j)(2)(i)-(3)(ii)) by four months. OSHA's HazCom rules establish requirements for employers that use chemicals as part of their regular workplace operations, including their products. Under these rules, employers must inform workers about chemical hazards through both labeling and training, and can face liability for failure to comply with these requirements.

The revised HazCom Standard requires chemical manufacturers and importers to list on warning labels the potential chemical reactions and dangers that occur when the chemical is mixed with other substances. Since the updated requirements were issued, chemical manufacturers and others in the regulated community have criticized the changes and sought clarification. In particular, manufacturers have raised concerns that the revised standard obligates them to anticipate potential consumer uses of their products and to bear the cost of updating HazCom notices accordingly. The final order also requires employers to update their HazCom programs and training to comply with the new standard, which may be a significant expense.

Recognizing some ambiguity and the need for clarification, OSHA has extended the initial compliance date in 29 CFR 1910.1200(j)(2)(i) by four months to allow time for the agency to publish the necessary guidance materials and for the regulated community to review those materials before the revised provisions take effect. Additionally, and consistent with this decision, OSHA delayed the other outlined HazCom deadlines as well. 

While manufacturers and employers have more time to comply with the revised HazCom Standard, they will eventually need to meet these requirements. Accordingly, it is important that businesses take note of the deadlines and use the additional time to prepare for compliance before the deadline. The revised deadlines for substances are:

• Manufacturers, importers, and distributors: May 19, 2026

• Employers (workplace labeling, written programs, training): November 20, 2026

Additionally, the revised deadlines for mixtures are:

• Manufacturers, importers, and distributors: November 19, 2027

• Employers (workplace labeling, written programs, training): May 19, 2028