Next HazCom Deadline Hits Nov. 20, 2026: SDS and Labeling Updates Due
Safety+Health Magazine reports that Nov. 20, 2026 marks the next major compliance date under OSHA’s revised Hazard Communication Standard, one of several staggered deadlines running through 2028. Per the outlet’s Q&A with a J. J. Keller & Associates compliance expert, chemical manufacturers and importers already had until May 19, 2026 to reclassify aerosols, desensitized explosives and flammable gases under new Appendix B criteria and revise SDSs and shipped container labels accordingly. The Nov. 20 deadline shifts responsibility to employers using these substances, who must update in-house labeling where hazard classifications changed, revise HazCom training programs, and train employees on any newly identified hazards. The underlying hazards aren’t changing, only how they’re classified. OSHA guidance cited in the article notes employers aren’t required to proactively request new SDSs from suppliers, but manufacturers must maintain and provide updated versions with shipments or upon request.
What It Means for Subcontractors
- Subs handling aerosols, desensitized explosives, or flammable gases on site (welding, coatings, fireproofing, insulation crews) should audit current SDS files now and confirm suppliers have sent updated versions ahead of the Nov. 20, 2026 deadline.
- Expect GCs to request proof of updated labeling and HazCom training records in prequalification packets before the deadline hits, so document any in-house label changes and refresher training sessions as they happen, not after.
- EHS managers should cross-check that the most recent SDS on file has replaced older versions per 1910.1200, since OSHA won’t require chasing down new SDSs but will expect the latest one maintained and accessible.
