Hazard Communication 2026: What the GHS Revision 7 Update Means for Your Compliance Program
OSHA's Hazard Communication Standard (29 CFR 1910.1200) was last significantly updated in 2012, when the agency aligned domestic HazCom requirements with the United Nations' Globally Harmonized System of Classification and Labelling of Chemicals (GHS). That update was the largest change to chemical safety communication in two decades.
In 2024, OSHA published its final rule updating HazCom again — this time aligning with GHS Revision 7. The compliance deadlines are phased: the first deadline, for hazardous substances, was May 19, 2026 — manufacturers, importers, and distributors should already be classifying and labeling to the updated criteria. Employer-side obligations for those substances follow on November 20, 2026, with the mixture deadlines extending through 2027 and 2028. If your chemical inventory, SDS library, and employee training materials haven’t been reviewed since 2012, they may not meet the updated standard.
What Changed in GHS Revision 7
New and Revised Hazard Categories
GHS Rev. 7 introduces new hazard categories and revises existing classification criteria for several chemical hazard classes. The most significant additions for industrial and manufacturing employers include expanded aerosol classifications, new categories for desensitized explosives, and revised criteria for acute toxicity characterization.
Chemicals that were classified under GHS Rev. 3 (which the 2012 update adopted) may require reclassification under Rev. 7. Manufacturers and importers have primary responsibility for reclassification — but employers who produce their own chemical products in-house, modify existing products, or create any chemical mixtures in their operations have their own classification obligations.
Updated SDS Requirements
Safety Data Sheets for substances covered by the new classification criteria must be updated to reflect the revised GHS Rev. 7 classifications. The 16-section SDS format remains the same — but Section 2 (Hazard Identification), Section 9 (Physical and Chemical Properties), and Section 11 (Toxicological Information) are most likely to require revision for affected chemicals.
For employers, the immediate obligation is to verify that the SDSs for chemicals in your inventory remain current. Suppliers are required to update SDSs when new information becomes available or when classification criteria change — but receiving updated SDSs requires that you have an active process for monitoring your chemical inventory and requesting current documentation from suppliers.
The SDS Audit Trigger
Any employer whose SDS library hasn't been systematically reviewed in the past 18 months should treat the 2026 HazCom update as a trigger for a full SDS audit. SDS documents are time-stamped. During an inspection, an SDS that is several years old for a chemical with recently revised classification criteria is a documentation vulnerability.
Revised Label Requirements
GHS Rev. 7 includes some revisions to label format requirements — specifically around the communication of concentration-dependent hazards and the labeling of small containers. The practical impact for most employers is limited unless they produce, repackage, or relabel chemicals. However, employers who create secondary container labels (spray bottles, transferred chemicals, diluted cleaning agents) need to verify that their secondary labeling practices meet the current GHS requirements.
Compliance Deadlines: What Applies When
OSHA’s phased compliance timeline for the 2024 HazCom update — the substance deadline has already passed; employer and mixture deadlines are still ahead:
May 19, 2026: (passed): Manufacturers, importers, and distributors were required to comply with the updated classification and labeling requirements for hazardous substances (single-ingredient chemicals)
November 20, 2026: Employers must implement substance-related workplace labels/program/training as necessary
November 19, 2027: Manufacturers, importers, and distributors must comply for hazardous mixtures
January 19, 2028: Distributors may ship products labeled under the previous standard until this date
May 19, 2028: Employers must implement mixture-related workplace labels/programs/training as necessary
For employers (users of chemicals), the practical compliance obligations are: maintain current SDSs that reflect the updated classifications as updated SDSs become available from suppliers; train employees on any new hazard information; update secondary container labels to reflect current GHS requirements; and revise written HazCom programs to reference the updated standard.
The Employee Training Requirement
OSHA requires that employees receive training on hazardous chemicals in their work area at initial assignment and whenever a new hazard is introduced. The introduction of new GHS Rev. 7 classifications for chemicals employees work with is a 'new hazard' trigger — meaning affected employees must receive updated training when their chemical inventory's SDSs are updated to reflect the new classifications.
The practical implication: employers cannot simply update their SDS library and assume compliance. They must ensure that employees whose work involves affected chemicals receive training on the updated hazard information. Training records must document that this update-triggered retraining occurred.
What to Do Now
For employers who haven't reviewed their HazCom program since 2012, the 2026 update is a good reason to do a compliance review that was already overdue. The practical checklist:
Conduct a full inventory of hazardous chemicals in your facility
Request updated SDSs from suppliers for every item on that inventory, and ask specifically for Rev. 7-compliant documentation where applicable
Review secondary container labeling practices for GHS compliance
Update your written HazCom program to reference the 2024 final rule
Train employees on updated hazard information for affected chemicals
Document the training with competency verification that shows employees understood the material
HazCom is rarely the only program that has drifted since it was written. If your facility uses respirators, the chemical inventory you're building now also drives respirator selection, and the same gaps tend to show up there too: a written program that no longer matches the site, training records that show attendance without comprehension, and documentation scattered across departments.
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CFR Compliance Group · 877-CFR-1910 · info@cfrcompliancegroup.com · cfrcompliancegroup.com