HazCom and GHS: Keep SDS and Labels Current
OSHA's 2024 HazCom update phases in by 2028. Between updates, SDS changes are due within three months and label changes within six.
In Short
- Substances: manufacturers comply by 19 May 2026.
- SDS updates within three months of new information.
- Label updates within six months.
The Chemical Manufacturing Guide
Approved formulas. Tested batches. Correct labels out the door.
- Which rules reach your plant
- Raw material to store
- Charge, watch, adjust, release
- Fill, label, ship and trace
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The Chemical Manufacturing Guide
Approved formulas. Tested batches. Correct labels out the door.
OSHA's Hazard Communication Standard (29 CFR 1910.1200) is the US workplace version of the UN GHS. OSHA amended it in 2024 with phased compliance dates. The EU applies GHS through the CLP Regulation (EC) No 1272/2008, which we did not reread for this update. Sources checked 3 Oct 2026 against the eCFR text current to 30 Sep 2026.
Compliance Dates
Paragraph (j) sets phased dates. Manufacturers, importers and distributors evaluating substances comply with the modified provisions by 19 May 2026, and for mixtures by 19 November 2027.
HazCom 2024 Compliance Dates
- 19 May 2026Manufacturers, importers, distributors: substances
- 20 Nov 2026Employers: substances
- 19 Nov 2027Manufacturers, importers, distributors: mixtures
- 19 May 2028Employers: mixtures
More on compliance Dates
Employers update labeling, programs and training by 20 November 2026 for substances and 19 May 2028 for mixtures. Check the current text before relying on a date.
The 16-Section SDS
Paragraph (g)(2) lists sixteen sections in a fixed order, from identification to other information, including the date of preparation or last revision. OSHA states it does not enforce sections 12 to 15, because those topics are outside its jurisdiction, but they are still included for GHS consistency.
When an SDS must change
Under paragraph (g)(5), new significant information about hazards or protective measures must be added to the SDS within three months of becoming aware of it. If the chemical is not currently produced or imported, the SDS is updated before it is introduced again.
New hazard information: what is due?
Pick a document.
- Paragraph (g)(5).
When labels must change
Under paragraph (f)(11), labels are revised within six months of becoming aware of significant new hazard information. Containers shipped after that time carry the revised label.
EU CLP is a separate system
CLP classification, labelling and poison-centre notification have their own rules and dates. A US SDS does not satisfy EU rules automatically, so keep region-specific documents from one controlled source and check the current CLP text.
Questions
When must we comply with the 2024 HazCom changes?
For substances, manufacturers, importers and distributors by 19 May 2026; for mixtures by 19 November 2027. Employer dates are 20 November 2026 and 19 May 2028 (29 CFR 1910.1200(j), eCFR text current to 30 Sep 2026).
How quickly must an SDS be updated?
Within three months of becoming aware of significant new information about hazards or protection (1910.1200(g)(5)).
How quickly must labels be updated?
Within six months of becoming aware of significant new hazard information (1910.1200(f)(11)).
Does V5 classify chemicals?
No. V5's safety data sheet module tracks hazard determinations, required sections, review and issue. Qualified people classify; V5 does not guarantee compliance.
Practical orientation, not legal advice. Rules differ by jurisdiction; your quality and compliance team decides what applies.
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EU REACH Registration and Supply Chain Duties for Chemical Makers
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TSCA Section 5 PMN: Who Files, the 90-Day Review and Notice of Commencement