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ARTICLE · 10 AUGUST 2026

OSHA Labels And Safety Data Sheets: Important Deadlines Ahead

Wiley Rein
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Chemical manufacturers and downstream users face critical compliance deadlines as OSHA's updated Hazard Communication Standard requires comprehensive revisions to safety data sheets, workplace labels, and employee training programs. The 2024 rule aligns U.S. standards with the UN's Globally Harmonized System Revision 7, introducing significant changes to hazard classifications, confidentiality provisions, and requirements for compressed gases and pressurized products.

United StatesEnvironment
Martha E. Marrapese
Martha E. Marrapese
Sara Beth Watson
Sara Beth Watson
Sarah E. Amick
Sarah E. Amick

Now that the deadline for chemical substance manufacturers and distributors to update their safety data sheets (SDSs) is in the rear view mirror, it is time for downstream users to start reviewing incoming ingredient SDSs and updating their own SDSs.

The need for these changes stems from the rule issued by the Occupational Safety and Health Administration (OSHA) in 2024 which updated the 2012 Hazard Communication Standard (Haz Com) to align with Revision 7 of the United Nations Globally Harmonized System of Classification and Labelling of Chemicals (GHS). 89 Fed. Reg. 44144. The revision is intended to further advance the GHS’s common and coherent approach for chemical hazard classification and communication on labels and safety data sheets, while also helping to reduce trade barriers.

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