In January, within just one week, the U.S. Occupational Safety and Health Administration (OSHA) issued two revisions to HCS 2024. On May 20, 2024, OSHA first released the 2024 revision of the Hazard Communication (HAZCOM) Standard (HCS) to align with the UN Globally Harmonized System (GHS) Seventh Revised Edition. This revised U.S. GHS regulation still did not introduce environment-related classifications.
On October 9, 2024, U.S. OSHA issued the first correction document for HCS. On January 8, 2026, U.S. OSHA issued the second correction document for the HCS final rule. Most corrections were minor typographical and technical errors that do not change any existing rights or obligations. The correction documents took effect upon publication.
This revision involves 44 technical errata and does not change the substantive compliance requirements of HCS 2024. Types of corrections mainly include:
- Additions to definitions and section headings;
- Deletion of redundant or erroneous text;
- Corrections to charts and formulas;
- Corrections to spelling errors and units;
- Updates to notes and explanations;
- Adjustments to label elements and precautionary statements;
The previous version was missing content on "chemicals under pressure." This correction supplements the relevant classification and labeling information to align with the UN GHS standards.
On January 15, 2026, U.S. OSHA also issued an extension of the HCS 2024 compliance deadlines by four months.
|
Latest Compliance Date |
Requirements |
Responsible Parties |
|
May 19, 2026 |
Update labels and Safety Data Sheets (SDS) for substances |
Chemical manufacturers, importers, distributors, and employers |
|
November 20, 2026 |
Update workplace labels, hazard communication programs, and training as needed |
Employers |
|
November 19, 2027 |
Update labels and SDS for mixtures |
Chemical manufacturers, importers, distributors, and employers |
|
May 19, 2028 |
Update workplace labels, hazard communication programs, and training as needed |
Employers |
Notably, among the corrections in the first published correction document, the more significant impact was the modification of the concentration cut-off threshold for reproductive toxicity:
The HCS 2024 revision had erroneously recorded the cut-off threshold as 0.01%; after correction, it has been restored to 0.1%, consistent with the previous HCS 2012 version.
CIRS Group reminds that the compliance date for substances has already passed, and updates to SDS and labels for mixtures still need to be expedited.
