Revised HCS November 20, 2026, Deadline for Employers Is Fast Approaching

As reported in our January 24, 2026, blog item, the U.S. Occupational Safety and Health Administration (OSHA) published a final rule on January 15, 2026, extending the compliance dates in its Hazard Communication Standard (HCS) (29 C.F.R. Section 1910.1200), published in the Federal Register on May 20, 2024 (89 Fed. Reg. 44144), by four months. 91 Fed. Reg. 1695. OSHA determined that it is necessary to extend the initial compliance date by four months to allow it time to publish the necessary guidance materials and for the regulated community to review those materials before the revised provisions take effect. Under the revised HCS, paragraphs (j)(2)(ii) and (j)(3)(ii) require employers to update any alternative workplace labeling under paragraph (f)(6), update the hazard communication program required by paragraph (h)(1), and provide any additional employee training in accordance with paragraph (h)(3) for newly identified hazards no later than November 20, 2026, for substances and May 19, 2028, for mixtures. More information on OSHA’s final rule amending the HCS is available in our May 30, 2024, memorandum. OSHA has posted a January 2026 guidance document entitled Hazard Communication: Hazard Classification Guidance for Manufacturers, Importers, and Employers. Other OSHA hazard communication guidance materials are available at https://www.osha.gov/hazcom/guidance.