If your business uses chemicals — solvents, cleaners, paints, pesticides, industrial products — you're covered by OSHA's [Hazard Communication Standard](/blog/what-is-hazcom) (29 CFR 1910.1200). And the rules just changed.

The HazCom 2024 final rule updates the standard to align with GHS Revision 7, introduces new hazard categories, and tightens requirements for safety data sheets, labels, and employee training. The compliance deadline for pure substances has already passed (January 2026). The deadline for mixtures is July 2027.

If you're not sure whether your business is compliant, this guide will walk you through what changed, what's required, and what to do next.

What Changed in HazCom 2024

The updated standard isn't a complete rewrite — it's a targeted update that closes gaps in the original 2012 revision. Here are the key changes that affect small businesses:

1. New Hazard Categories

HazCom 2024 adds new hazard classifications that weren't in the previous version:

Desensitized explosives
Non-flammable aerosols
Chemicals under pressure
Mild skin irritation (Category 3)
Eye irritation (Category 2B)

If any of your products fall into these new categories, their SDSs and labels need to be updated.

2. Updated SDS Requirements

Safety Data Sheets now require additional information:

Nanoparticle/nanomaterial identification
Updated concentration ranges for trade secret claims
Clearer guidance on how to describe hazards for mixtures
Specific formatting requirements for Section 9 (physical and chemical properties)

If you're still using SDSs from 2020 or earlier, they may not meet the new requirements.

3. Label Changes

Labels must now include:

Small container labeling provisions (for containers 100 mL or less)
Updated precautionary statements aligned with GHS Rev 7
Clarified requirements for workplace labels vs. shipped container labels

4. Training Updates

Any time the standard changes, OSHA expects you to retrain employees on the new requirements. That means every worker who handles chemicals needs updated HazCom training that covers:

The new hazard categories
How to read the updated SDSs
What the new label elements mean

What OSHA Requires: The 6 Elements of a HazCom Program

Whether you have 5 employees or 500, OSHA requires every employer to maintain a complete Hazard Communication program. Here's what that includes:

1. Written HazCom Plan

A written document that describes how your company implements the HazCom standard. It must include:

Who is responsible for maintaining the program
How SDSs are maintained and made accessible
How employees are informed about chemical hazards
How you handle non-routine tasks involving chemicals
How you inform contractors about chemical hazards on-site

2. Chemical Inventory

A complete list of every hazardous chemical in your workplace. This should include:

Product name (as it appears on the SDS)
Location where the chemical is used or stored
Quantity on hand

3. Safety Data Sheets (SDSs)

You must maintain a current SDS for every hazardous chemical in your inventory. SDSs must be:

Readily accessible to employees during their shift
No more than 3 years old (best practice — OSHA doesn't set a hard expiration, but outdated SDSs are a common citation)

4. Labels

Every chemical container in your workplace must be labeled with:

Product identifier (matching the SDS)
Signal word (Danger or Warning)
Hazard statements
Pictograms
Precautionary statements
Supplier information

Secondary containers (spray bottles, transfer containers) need simplified workplace labels at minimum.

5. Employee Training

Every employee who works with or near chemicals must be trained on:

The location and availability of the written HazCom plan and SDSs
How to read and understand SDSs and labels
Physical and health hazards of the chemicals in their work area
Protective measures (PPE, ventilation, emergency procedures)

Training must be documented, and employees must be retrained when new chemicals are introduced or the standard changes.

6. Hazard Assessment

Your program must identify the specific hazards present in each work area and ensure that appropriate controls (engineering controls, PPE, training) are in place.

What Happens If You're Not Compliant

HazCom violations are consistently among OSHA's top 10 most-cited standards. Here's what's at stake:

Serious violation: Up to $16,131 per violation
Willful or repeated violation: Up to $161,323 per violation
Common citations: Missing SDSs, incomplete training records, unlabeled secondary containers, no written plan

A single OSHA inspection that finds multiple HazCom issues can result in fines exceeding $50,000 — and that's for a small business.

How to Get Compliant: A Step-by-Step Checklist

Here's what you need to do, in order:

Audit your [chemical inventory](/blog/ehs-chemical-inventory-management-guide) — Walk every work area and list every chemical product. Include cleaning supplies, lubricants, solvents, paints, adhesives, and anything with an SDS.

2. Collect current [SDSs](/blog/what-is-sds) — Make sure you have a current SDS for every product on your list. If any are missing or outdated, request updated versions from your suppliers.

3. Check your [labels](/blog/ghs-label-requirements-osha) — Verify that every container has proper labeling. Pay special attention to secondary containers — spray bottles, pour containers, and transfer vessels.

4. Write (or update) your HazCom plan — If you don't have a written plan, create one. If you have one, update it to reference the HazCom 2024 changes.

5. Train your employees — Conduct updated training that covers the new hazard categories, SDS format, and label requirements. Document attendance.

6. Assess your hazards — Review each work area for chemical hazards and ensure appropriate PPE and controls are in place.

7. Make SDSs accessible — Employees must be able to access SDSs during their shift. A locked filing cabinet in the manager's office doesn't count. Digital access via a phone or tablet is the modern solution.

8. Set up ongoing maintenance — HazCom isn't a one-time project. You need a system to update SDSs when products change, train new hires, and keep your inventory current.

The Paper Binder Problem

Most small businesses manage HazCom compliance with a paper binder. Here's why that's risky:

Binders go out of date the moment a product changes
New employees don't know where the binder is (or that it exists)
Night shift, field workers, and remote sites can't access it
OSHA inspectors can see immediately if it hasn't been maintained
When OSHA asks "show me the SDS for this product," fumbling through a binder is not a good look

Digital SDS management solves all of these problems. Your team accesses everything from their phone. SDSs are always current. Training is tracked automatically. And when OSHA walks in, you show them the app.

Key Deadlines

January 19, 2026: Compliance deadline for pure substances (single-chemical products)
July 19, 2027: Compliance deadline for mixtures (multi-chemical products)
Now: Employee training on the updated standard should be happening already

Getting Started

If you're reading this and thinking "we're behind," you're not alone. Most small businesses are. The good news is that getting compliant doesn't take months — with the right tools, it takes days.

Start with a chemical inventory audit this week. That's step one, and it tells you exactly how big the project is.

If you want help, Tellus EHS can automate most of this — from SDS management and chemical inventory to training tracking and HazCom plan generation. But even if you do it manually, the steps above will get you there.

The important thing is to start before OSHA starts for you.