By 20 November 2026, an employer covered by OSHA's Hazard Communication Standard must, as necessary, update its workplace labels and its written hazard communication program, and give additional training on hazards newly identified in updated labels and safety data sheets (SDSs) for substances1. That is 29 CFR 1910.1200(j)(2)(ii). A final rule published 15 January 2026, 91 FR 1695, moved the date from 20 July 20262.

The November deadline does not require blanket retraining: training is owed where a hazard is new to your staff3. Mixtures follow on 19 May 20281. 29 CFR 1910.1200 applies to home care and home health on the same terms, because OSHA coverage does not depend on Medicare certification4.

What is the OSHA HazCom deadline in 2026?

The OSHA HazCom deadline for employers is 20 November 2026 for substances and 19 May 2028 for mixtures, and at each date the updates are owed "as necessary"15.

  • 20 November 2026, employers, substances. Update workplace labels, the hazard communication program and training, as necessary. 29 CFR 1910.1200(j)(2)(ii)15.
  • Moved from 20 July 2026 by the final rule at 91 FR 1695, published 15 January 20262.
  • 19 May 2028, employers, mixtures. The same 3 tasks. 29 CFR 1910.1200(j)(3)(ii)15.
  • Until each date, an employer may comply with the 2012 version of the standard, the 2024 version, or both. 29 CFR 1910.1200(j)(4)13.
  • No later change to these dates appeared in the Federal Register as of 25 September 20266.

If your state runs its own OSHA-approved State Plan, its dates may differ7.

For substances, all employers shall, as necessary, update any alternative workplace labeling used under paragraph (f)(6) of this section, update the hazard communication program required by paragraph (h)(1) of this section, and provide any additional employee training in accordance with paragraph (h)(3) of this section for newly identified physical hazard, or health hazards or other hazards covered under this section no later than November 20, 2026.

29 CFR 1910.1200(j)(2)(ii)1

Does every aide have to be retrained by 20 November?

No. 29 CFR 1910.1200(j)(2)(ii) asks for "additional" training, "as necessary", on "newly identified" hazards, not a new round of HazCom training for every employee1.

OSHA's inspection directive for the 2024 rule, CPL 02-02-079, says: "The requirement for an employer to provide updated training is based on the hazard, not the chemical"3. Its example: "if an employee is working with one flammable solvent and a second flammable solvent is introduced, the training does not need to be updated. However, if the employee is working with a flammable solvent and a corrosive is introduced, the training needs to be updated"3.

For users of reclassified chemicals, OSHA wrote in its 2024 economic analysis that it "does not believe that these users would need to dedicate more than a trivial amount of time to training associated with the reclassification of these chemicals," because "the hazards associated with these chemicals have not changed"8.

OSHA's directive says the extra time "allows the employer to review all the new information received as a result of the revisions and provide new training, if necessary"3. If no product your staff use brings a new hazard, reviewing labels and the written program is most of your November work.

Does HazCom apply to home care as well as home health?

Medicare certification does not change the answer: 29 CFR 1910.1200 applies to home care and home health agencies on the same terms4. Whether HazCom reaches your staff turns on whether they may be exposed to hazardous chemicals under normal conditions of use, and then on the consumer-product exemption1.

Under 29 CFR 1910.1200(b)(6)(ix), the standard does not apply to "Any consumer product or hazardous substance, as those terms are defined in the Consumer Product Safety Act (15 U.S.C. 2051 et seq.) and Federal Hazardous Substances Act (15 U.S.C. 1261 et seq.) respectively, where the employer can show that it is used in the workplace for the purpose intended by the chemical manufacturer or importer of the product, and the use results in a duration and frequency of exposure which is not greater than the range of exposures that could reasonably be experienced by consumers when used for the purpose intended"1. The directive says it is OSHA's policy not to cite for consumer products unless the inspector can document that the product was used in a manner the manufacturer did not intend, or that the frequency and duration of use result in exposures significantly greater than a normal consumer's3.

It also gives 2 cleaning examples. "A product would not be covered by HCS if a worker chooses to clean their personal workspace with a product that is meant for cleaning purposes." "Employers would be required to comply with HCS if a worker's job duty includes custodial work such as cleaning desks, offices, and bathrooms."3

How OSHA would treat an aide cleaning a client's home with the client's own products is an open question. CPL 02-02-079 does not address that case, and this page does not decide it for you3. The answer turns on how your aides use each product and how often, facts only your agency has1.

What changed in the 2024 HazCom rule?

The 2024 rule changed how hazards are classified and what labels and safety data sheets show; it did not change when you must train185.

What changedBefore (HCS 2012)After (HCS 2024)What it means for a home care or home health employerSource
Employer compliance date, substancesn/a20 July 2026 in the 2024 rule, now 20 November 2026The date on this page91 FR 16952; 1910.1200(j)(2)(ii)1
Employer compliance date, mixturesn/a19 January 2028 in the 2024 rule, now 19 May 2028A second clock91 FR 16952; 1910.1200(j)(3)(ii)1
Hazard classification, (d)(1)Intrinsic hazardsAdds hazards from a change in physical form and from reaction products of known or reasonably anticipated usesManufacturers classify; employers are not required to unless they choose not to rely on the manufacturer1910.1200(d)(1)1; OSHA Q&A5
Physical hazard classes, Appendix BNo nonflammable aerosol category; no desensitized explosives classAerosols gain a category (nonflammable aerosols); flammable gases split into 1A and 1B; desensitized explosives addedIf a product your staff use is an aerosol, its new label may show a new category. OSHA judged the added training for users of reclassified chemicals trivial, because the hazards did not change89 FR 44316 and 89 FR 44223 to 442248; OSHA Q&A5
Small containers, (f)(12)No specific provision (handled by letters of interpretation)100 ml or less: product identifier, pictogram, signal word, manufacturer name and phone, and a pointer to the outer package. 3 ml or less: product identifier only, where a label would interfere with useSmall bottles may carry a shortened label; the full label is on the outer package1910.1200(f)(12)1; 89 FR 441488; OSHA Q&A5
Labels on stock already shipped, (f)(11)RelabelOption not to relabel containers released for shipment, if the updated label ships with each containerUpdated labels can arrive separately from the product1910.1200(f)(11)1; OSHA Q&A5
Safety data sheets, Appendix D2012 formatSections 2, 3, 9 and 11 revisedNew SDSs will look slightly different; the 16-section order is unchangedOSHA Q&A5; 1910.1200(g)(2)1
Trade secrets, (i)Concentration could be withheldWithheld concentrations must use prescribed rangesSection 3 of an SDS may show a range, not an exact percentage1910.1200(i)1; OSHA Q&A5
Employer training duty, (h)(1)At initial assignment and whenever a new hazard is introducedUnchanged. The 2024 rule adds only "any additional employee training … for newly identified" hazards by each dateTraining is owed where a hazard is new, not across the board1910.1200(h)(1) and (j)(2)(ii)1; CPL 02-02-0793

Is HazCom training required annually?

No. 29 CFR 1910.1200(h)(1) requires training "at the time of their initial assignment, and whenever a new chemical hazard the employees have not previously been trained about is introduced into their work area", with no annual cycle and no hour count41. That is the federal rule; your state may require more7.

The annual cycle belongs to bloodborne pathogens. 29 CFR 1910.1030 is a separate standard and requires training at least annually; 29 CFR 1910.1200(b)(6)(xii) leaves biological hazards outside HazCom91. Bloodborne pathogens training for home health agencies covers that cycle.

What does an employer have to do by 20 November 2026?

By 20 November 2026, you have to know whether HazCom reaches your staff, and have labels, the written program and training current for every newly identified hazard13. The 9 steps, in order:

  1. Decide whether HazCom reaches your staff at all. Settle the consumer-product exemption, 29 CFR 1910.1200(b)(6)(ix), and OSHA's citation policy for it13.
  2. Check that the written program exists and lists the hazardous chemicals known to be present. 29 CFR 1910.1200(e)(1)1.
  3. Keep the most recent SDS for each chemical. A 2024-format SDS replaces the 2012 one when it arrives; an older SDS for a product not recently received stays compliant unless a new one was provided and not kept3.
  4. Compare each updated SDS or label with what staff were trained on. Train again only where a hazard is new, not a chemical3.
  5. Train in a language and at a literacy level staff understand, on paid time, with a chance to ask questions. Handing out SDSs to read does not satisfy the rule on its own3.
  6. Update any alternative workplace labeling you use. 29 CFR 1910.1200(f)(6) and (j)(2)(ii)1.
  7. Write into the program how staff working away from the office reach SDS information. 29 CFR 1910.1200(e)(5) and (g)(9)13.
  8. If your state runs an OSHA-approved State Plan, check its own adoption date75.
  9. Put 19 May 2028 on the calendar for mixtures. 29 CFR 1910.1200(j)(3)(ii)1.

29 CFR 1910.1200(h) contains no training-record or retention requirement1. Keep one anyway, so you can show who was trained on what. Records that other rules require are a separate check.

How does an aide in a client's home get to a safety data sheet?

The duty that matters in a client's home is in 29 CFR 1910.1200(g)(9): "the employer shall ensure that employees can immediately obtain the required information in an emergency"1. It is the price of keeping SDSs at the office: where work is "carried out at more than one geographical location", (g)(9) lets you keep them at the primary workplace facility, and 29 CFR 1910.1200(e)(5) lets the written program stay there too1.

OSHA's inspection directive says access can come through a representative who is always available, or by email, smartphone or tablet. Either way, the directive says your written program must state how SDS information reaches remote worksites3.

CPL 02-02-079's own example is a construction worksite. Applying it to an aide in a client's home is one reading of the rule's wording in 29 CFR 1910.1200(g)(9), not a position OSHA has stated for home care or home health13.

What happens after 20 November, and what about mixtures?

After 20 November 2026, your next date is 19 May 2028, when the same updates fall due for mixtures under 29 CFR 1910.1200(j)(3)(ii)1. That date was 19 January 2028 before the January 2026 extension2.

Your old SDSs do not expire on either date: a 2012-format SDS stays compliant until a 2024-format one arrives and replaces it3.

Does my state have a different date?

It may. 22 State Plans cover private-sector workers as well as state and local government workers. Each must be at least as effective as OSHA, so a State Plan with its own HazCom standard can adopt the 2024 changes on different dates75.

If your state runs a State Plan, check its HazCom adoption date before relying on the dates on this page7.

How to do it yourself

You can meet the 20 November 2026 date with the staff already on payroll and free material. For an agency whose staff handle a short list of products, plan on 1 to 2 working days of office time, plus one short session for each new hazard you find.

The free tools:

  • OSHA's own material. The HazCom pages at osha.gov/hazcom10, the inspection directive CPL 02-02-0793, OSHA's Q&A on the 2024 update5 and the rule text on eCFR1.
  • The SDS for each product, from the manufacturer or your supplier.
  • A written program you write yourself, from the outline in step 4.

The steps:

  1. List every product your staff handle. Cover what the agency supplies, what aides and nurses carry, and what they use in clients' homes. For each product, note who supplies it, how often staff use it and in what amounts. Those facts decide the consumer-product question in 29 CFR 1910.1200(b)(6)(ix), product by product13.
  2. Collect the most recent SDS for each product that stays on the list. A 2024-format SDS replaces the 2012 one when it arrives3.
  3. Compare each new SDS or label with what staff were trained on. Sections 2, 3, 9 and 11 are the revised ones, so read those first5. It can stall here: an updated SDS may not have arrived, and the 2012-format one stays compliant until it does3. Mark a product only if its hazard is new to your staff, not because the chemical is new3.
  4. Write or update the written program. An outline built only from the rules on this page13:
    • the hazardous chemicals known to be present, 29 CFR 1910.1200(e)(1);
    • any alternative workplace labeling you use, (f)(6);
    • where SDSs are kept and how an aide in a client's home reaches one in an emergency, (e)(5) and (g)(9);
    • when you train: at initial assignment and whenever a new hazard is introduced, (h)(1);
    • your State Plan's dates, if you are in one, and 19 May 2028 for mixtures.
  5. Give additional training on the hazards step 3 marked. Free material such as OSHA's covers what 29 CFR 1910.1200 makes the same at every employer: label elements, pictograms and the 16-section SDS format110. Give the session on each new hazard in a language and at a literacy level your staff understand, on paid time, with a chance to ask questions3.
  6. Record who was trained, on what, on which date and in which language. The rule does not require the record1; it is how you show the training happened.
  7. Put the next checks on the calendar: your State Plan's adoption date, if you are in one7, and 19 May 2028 for mixtures1.
TaskWho can do itRough time
Product list and use notes (step 1)Administrator with a field supervisor2 to 4 hours
SDS collection (step 2)Office staff1 to 3 hours
SDS and label comparison (step 3)Anyone who can read an SDS10 to 20 minutes a product
Written program (step 4)Administrator2 to 4 hours, less if one exists
Training on a new hazard (step 5)Supervisor or nurse1 short session a hazard
Training record (step 6)Office staffMinutes a session

These times are working estimates for a short product list, not OSHA figures; a long list or a State Plan adds time. OSHA expected users of reclassified chemicals to need no more than "a trivial amount of time" for the training8. If step 3 finds no new hazard, step 5 is empty.

The 3 mistakes that cost the most

  1. Retraining every aide on everything. The rule asks for additional training, as necessary, on newly identified hazards1. A full HazCom round for every employee spends paid hours on hazards your staff already know3.
  2. Handing out SDSs and calling it training. OSHA's directive says that does not satisfy the rule on its own3.
  3. Claiming the consumer-product exemption without the facts behind it. The exemption applies only "where the employer can show" the product is used as the manufacturer intended, at no more than a consumer's duration and frequency of exposure1. If your step 1 notes cannot show that, the exemption does not help you.

Questions people also ask

Is HazCom training required annually? No. 29 CFR 1910.1200(h)(1) requires HazCom training at initial assignment and whenever a new chemical hazard is introduced into the work area, with no annual cycle1.

Does HazCom apply to a non-medical home care agency? It can. OSHA coverage does not depend on Medicare certification, and whether HazCom reaches a home care agency's staff turns on the consumer-product exemption in 29 CFR 1910.1200(b)(6)(ix)41.

Does every old SDS have to be replaced by 20 November? No. Keep the most recent SDS for each product; an older SDS for a product not recently received stays compliant unless a new one was provided and not kept3.

Is there a minimum number of HazCom training hours? No. 29 CFR 1910.1200(h) sets no hour count1.

Does HazCom cover bloodborne pathogens? No. 29 CFR 1910.1200(b)(6)(xii) leaves biological hazards outside HazCom; bloodborne pathogens falls under 29 CFR 1910.1030, which requires training at least annually19.

  1. 29 CFR 1910.1200, Hazard Communication, current text on eCFR (point in time 23 September 2026), read 25 September 2026. https://www.ecfr.gov/current/title-29/subtitle-B/chapter-XVII/part-1910/subpart-Z/section-1910.1200 ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎

  2. Federal Register, "Hazard Communication Standard", final rule, extension of compliance dates, 91 FR 1695 to 1696, FR Doc 2026-00653, published and effective 15 January 2026. https://www.federalregister.gov/documents/2026/01/15/2026-00653/hazard-communication-standard ↩︎ ↩︎ ↩︎ ↩︎ ↩︎

  3. OSHA Instruction CPL 02-02-079, "Inspection Procedures for the Hazard Communication Standard (HCS 2024)", signed 30 April 2026, effective 19 May 2026. https://www.osha.gov/sites/default/files/enforcement/directives/CPL-02-02-079_0.pdf ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎

  4. 29 CFR 1910.1200(h), Hazard Communication, employee information and training, verified 25 September 2026. https://www.ecfr.gov/current/title-29/subtitle-B/chapter-XVII/part-1910/subpart-Z/section-1910.1200 ↩︎ ↩︎ ↩︎ ↩︎

  5. OSHA, "Questions & Answers for OSHA's 2024 Update to the Hazard Communication Standard (HCS)", undated, read 25 September 2026. https://www.osha.gov/sites/default/files/HCS_Q-and-As_2026.pdf ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎

  6. Federal Register, all documents under RIN 1218-AC93, newest first, searched 25 September 2026. https://www.federalregister.gov/api/v1/documents.json?conditions[regulation_id_number]=1218-AC93&order=newest ↩︎

  7. OSHA, "State Plans", read 25 September 2026. https://www.osha.gov/stateplans ↩︎ ↩︎ ↩︎ ↩︎ ↩︎ ↩︎

  8. Federal Register, "Hazard Communication Standard", final rule, 89 FR 44144, FR Doc 2024-08568, 20 May 2024, effective 19 July 2024. https://www.federalregister.gov/documents/full_text/text/2024/05/20/2024-08568.txt ↩︎ ↩︎ ↩︎ ↩︎ ↩︎

  9. 29 CFR 1910.1030(g)(2)(iv), Bloodborne pathogens, annual training, read 25 September 2026. https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1030 ↩︎ ↩︎

  10. OSHA, "Hazard Communication", read 25 September 2026. https://www.osha.gov/hazcom ↩︎ ↩︎