Background: OSHA’s Revised Hazard Communication Standard
Effective hazard communication remains one of the foundational elements of workplace health and safety programs. Employers that manufacture, distribute, or use hazardous chemicals are responsible for ensuring employees understand the hazards they may encounter and have access to appropriate safety information.
On May 19, 2026, the Occupational Safety and Health Administration (OSHA) issued updated enforcement guidance for its revised Hazard Communication Standard (HazCom), 29 CFR 1910.1200. The directive replaces OSHA’s 2015 enforcement guidance and provides compliance officers with detailed instructions for evaluating employer compliance during workplace inspections.
The enforcement guidance supports OSHA’s 2024 revisions to the Hazard Communication Standard, which aligned the regulation more closely with Revision 7 of the United Nations’ Globally Harmonized System of Classification and Labelling of Chemicals (GHS). The 2024 update revised hazard classifications, labeling requirements, Safety Data Sheet (SDS) content, and trade secret provisions.
While the revised Hazard Communication Standard was finalized in 2024, the new enforcement directive offers important insight into how OSHA will approach inspections during the implementation period. For employers, the guidance provides an opportunity to review existing management systems and programs to ensure compliance with upcoming deadlines.
Key Elements in OSHA’s New Enforcement Directive
- Increased Focus on Written Hazard Communication Programs
The directive emphasizes the importance of maintaining a comprehensive written Hazard Communication Program. During inspections, OSHA compliance officers may evaluate whether employers have developed, implemented, and maintained programs that address all required elements.
- Enhanced Review of Safety Data Sheets (SDSs)
The updated directive provides extensive guidance regarding SDS requirements and employer responsibilities.
- Greater Emphasis on Workplace Labeling
Workplace labeling remains a common area of concern during OSHA inspections.
- Continued Focus on Employee Information and Training
Employee training remains a critical component of Hazard Communication compliance.
- Transition Deadlines Are Approaching
Chemical manufacturers, importers, and distributors are required to comply with updated requirements for chemical substances by May 19, 2026. Employers have until November 20, 2026, to update workplace hazard communication programs, workplace labels, and employee training as necessary to reflect revised hazard information for chemical substances.
What Does OSHA’s New HazCom Enforcement Directive Mean for Employers?
The updated enforcement directive signals OSHA’s continued focus on Hazard Communication compliance and provides a clearer picture of what compliance officers may evaluate during inspections.
Organizations that manufacture, distribute, store, or use hazardous chemicals may benefit from reviewing written Hazard Communication Programs, chemical inventories, Safety Data Sheet management systems, workplace labeling practices, employee training records, and contractor communication procedures before the November 2026 compliance deadline.
Where Many Organizations May Need Additional Support for OSHA’s New HazCom Enforcement Directive
The revised enforcement directive highlights several areas where organizations may discover compliance gaps as they prepare for the November 2026 deadline. Common challenges include:
- Maintaining complete and current Safety Data Sheet (SDS) libraries for all hazardous chemicals in use.
- Evaluating whether SDSs received from suppliers meet updated GHS Revision 7 requirements.
- Reconciling chemical inventories with available SDSs and workplace labeling systems.
- Updating written Hazard Communication Programs to reflect revised hazard classifications and SDS information.
- Ensuring employee training materials and procedures align with updated hazard information.
- Verifying contractor communication procedures for hazardous chemicals present onsite.
Organizations conducting internal compliance reviews now may be better positioned to identify and address deficiencies before OSHA inspections occur.
How RHP Risk Management Can Help Your Organization with OSHA’s New HazCom Enforcement Directive
RHP Risk Management supports organizations in developing, evaluating, and improving occupational health and safety programs, including Hazard Communication compliance programs.
As organizations prepare for the November 2026 compliance deadline, conducting a proactive Hazard Communication gap assessment can help identify potential deficiencies before an OSHA inspection occurs. Our Certified Industrial Hygienists (CIHs), Certified Safety Professionals (CSPs), and occupational health and safety consultants assist organizations with Hazard Communication Program reviews, SDS audits, chemical inventory evaluations, workplace labeling assessments, employee training, and comprehensive compliance audits.
Contact RHP to learn more about our industrial hygiene, occupational health, and OSHA compliance consulting services or call (866) 481-8188 to schedule an initial consultation.