OSHA HazCom update
(GHS Revision 7)
A practical guide to compliance, training, and audits
Overview
OSHA’s updated Hazard Communication Standard (HazCom)—aligned with GHS Revision 7—introduces new requirements that impact how organizations manage Safety Data Sheets (SDSs), labeling, training, and audits.
With the May 19, 2026 deadline approaching for updating substance labels and SDSs, many organizations are asking the same question:
What do we actually need to do to be compliant and ready for an inspection?
This guide breaks that down into practical steps, based on how compliance works in real environments—not just on paper.
For official guidance, refer to OSHA:
https://www.osha.gov/hazcom
What this guide covers
This series walks through HazCom compliance from end to end:
Understanding what changed and what it means
Building a repeatable audit process
Training employees effectively (and proving it)
Managing SDSs, labels, and regulatory references
Tracking and resolving compliance gaps
Preparing for OSHA inspections
GapCross helps teams move from compliance to control with risk-based, system-level visibility.
Important dates
On January 15, 2026, OSHA extended all of the compliance dates for the updates to the Hazard Communication Standard by four months. For more details, see the Federal Register notice.
Compliance date: May 19, 2026
(18 months after effective date)
Requirement(s): Update labels and SDSs for substances
Who: Chemical manufacturers, importers, distributors and employers
Compliance date: November 20, 2026
(24 months after effective date)
What: Update workplace labels, hazard communication program and training as necessary
Who: Employers
Compliance date: November 19, 2027
(36 months after effective date)
Requirement(s): Update labels and SDSs for mixtures
Who: Chemical manufacturers, importers, distributors and employers
Compliance date: May 19, 2028
(42 months after effective date)
Requirement(s): Update workplace labels, hazard communication program and training as necessary
Who: Employers
Transition Period: July 19, 2024 to the effective completion dates noted above *
Requirement(s): May comply with either 29 CFR 1910.1200 (this final standard), or the previous standard, or both
Who: Chemical manufacturers, importers, distributors, and employers
* During this transition period, employers may comply with either the HCS effective on October 1, 2023 or the final rule published on May 20, 2024.
Preparing for OSHA HazCom updates: What you actually need to do before May 19, 2026
OSHA’s HazCom update includes an upcoming compliance deadline for SDS and labeling changes. The real challenge is coordinating updates across training, audits, and documentation to be ready.