HazCom 2024 retraining checklist: six phases to finish before November 20, 2026

A HazCom 2024 retraining checklist has six phases: confirm your chemical inventory and collect updated SDSs, fix workplace labels, revise the written program, write the retraining content, deliver it to the exposed workers, and file a dated record. All six need to be finished for substances by November 20, 2026, the employer date in OSHA's extended schedule.

We built this list for plant and facility teams who already understand the rule and now need a task list they can assign and tick off. If you want the background first (what changed from HazCom 2012, every compliance date and who is in scope), read our HazCom 2024 training requirements guide. We use LMS Advisor, our own product, for the delivery and records steps further down. It is not an OSHA-authorized trainer, and nothing in this post is legal advice.

What has to be done before November 20, 2026?

Three things, and only for substances at this stage. Paragraph (j)(2)(ii) of 29 CFR 1910.1200 requires every employer to update alternative workplace labeling, update the hazard communication program and provide any additional employee training for newly identified hazards. OSHA set that date in its January 15, 2026 extension rule, four months later than the July 20, 2026 date in the original 2024 rule.

Mixtures follow on May 19, 2028. Suppliers had until May 19, 2026 to update substance labels and SDSs, so most of the new paperwork should already be in your receiving area or inbox. If it isn't, that is your first call.

One detail changes how much work you face. The standard asks for additional training on hazards that are new to your workers, not a full repeat of the original HazCom course. A plant where only three of forty products were reclassified has a much smaller job than one where half the solvent shelf changed.

The HazCom 2024 retraining checklist, phase by phase

Work through the phases in order. Each one feeds the next: you cannot write training until you know which hazards changed, and you cannot evidence it until you know who was supposed to take it.

How do you decide who needs retraining?

Start from the hazard list you built in phase 1, not from the employee roster. The steps below keep the scope honest.

1. Map products to work areas. Your inventory already says where each product is used. Add the job titles that handle it.
2. Map work areas to people. Pull the department and shift roster for each area. Include temporary and agency staff who work there.
3. Cross the two lists. Anyone who handles a product with a newly identified hazard is in scope for retraining on that hazard.
4. Add the label readers. Receiving, shipping, warehouse and lab staff see small-container labels and separately shipped labels every week, so give them the label lesson even if no product they touch was reclassified.
5. Add the supervisors. They will field the questions. Give them the whole course plus the written program changes.
6. Write the list down. The assignment list is part of your evidence, because it shows you thought about scope.

Training under paragraph (h)(1) has to be "effective," so a worker who cannot read the course language has not been trained. That is the reason the translation step sits in phase 4 and not at the end.

Sample 8-question HazCom 2024 knowledge check

Use these as a starting point and replace the site-specific answers with your own. Questions 6 to 8 should name your actual products and locations.

1. A container holds 50 ml of a hazardous chemical and has no room for a full label. What must it show at a minimum? Answer: the product identifier, pictograms, signal word, the manufacturer's name and phone number, and a statement that the full label is on the outer package.
2. A 2 ml vial shows only a product name. Where do you find the rest of the label? Answer: on the immediate outer package, which is where the vial should be stored when not in use.
3. A pallet arrives with an extra label sheet in the paperwork for drums that were already packed. Is that normal? Answer: yes. Stock already released for shipment does not have to be relabeled, but the updated label must come with each container, so it goes on the drum or with it as your program says.
4. How many sections does a safety data sheet have, and has the order changed under HazCom 2024? Answer: 16 sections, and the order is the same. Appendix D adds required items to Sections 2, 3, 9 and 11, for example particle characteristics in Section 9 and interactive effects in Section 11.
5. Name two ways you might notice a chemical release in your work area. Answer: examples include an odor, a visible vapor or spill, a monitoring alarm, or symptoms such as eye or throat irritation. Use the detection methods in your own program.
6. Which product in your area has a newly identified hazard, and what is it? Answer: site-specific, taken from your phase 1 list.
7. What PPE does that hazard now call for at your station? Answer: site-specific, taken from the updated SDS and your program.
8. Where are the written hazard communication program and the SDSs kept on your shift? Answer: site-specific, for example the binder at the supervisor's desk or a named shared drive or kiosk.

Set the pass mark at 7 of 8 and allow a retake. A wrong answer on questions 6 or 7 is worth a supervisor conversation, not just a retake.

A small-employer version

A shop with fewer than about 25 people and a short chemical list does not need a project plan. It needs one afternoon and one file folder. This is the cut-down version.

1. Inventory in an hour. List every product on the shelf. Circle the ones that are single substances.
2. Get the new SDSs. Email each supplier and ask for the SDS updated to the 2024 standard. Compare old and new and write down any new hazard.
3. Fix the labels you made yourself. Spray bottles, transfer cans and totes are your responsibility. Supplier labels are theirs.
4. Update the written program. Change the chemical list, the date and a paragraph on small-container labels. One page is fine if it covers your site.
5. Hold one 20 to 30 minute meeting. Walk through the new hazards, show a real small-container label and the SDS, and say where the program lives.
6. Give the 8-question check on paper or on a phone. Keep the scored answers.
7. File the evidence. A sign-in sheet with the date, topics and trainer, the scored checks and the updated program, in one folder.

If even one product changed and someone handles it, do the meeting. No hazard changes at all still leaves the label and SDS briefing, which takes 10 minutes.

How to run HazCom retraining in LMS Advisor

Once the content exists, LMS Advisor handles delivery and the evidence trail. Each checklist phase maps to a feature we can point to.

Two limits to plan around. LMS Advisor sends no reminder emails before a due date, so someone should run the overdue report each week in November. And it supplies no HazCom course: your team writes it, or uploads a licensed SCORM package. More on assignments and reports is on our compliance training page, and you can book a demo to see the export.

What records should you keep after retraining?

The standard does not prescribe a training record. Keep one anyway, because it is your only proof that the November 20, 2026 training happened and that people understood it. A useful record has:

• Each employee's name, department and shift
• The date of the training and the course or session name
• The hazards or products covered
• Who delivered the floor session, if there was one
• The knowledge check score
• The version and date of the written program it matched

How long to keep it depends on your other obligations. Our training records retention guide lines up the US rules that set periods.

Frequently asked questions

What should a HazCom 2024 retraining checklist include?

It should cover inventory and SDS review, workplace labels, the written program, training content, delivery and records. Each phase depends on the one before it, starting with a list of newly identified hazards from updated SDSs.

Is the November 20, 2026 date for all chemicals?

No. It covers substances. For mixtures, the employer date is May 19, 2028, under the dates OSHA set in January 2026.

How long should HazCom 2024 retraining take?

As long as it takes to cover the hazards that changed in that worker's area, since 1910.1200 sets no minimum length. In our experience a short, specific session with a scored check is easier to evidence than a long generic video.

Can we use a supplier's generic HazCom 2024 video?

As part of it, yes. The standard requires training on the hazards in the employee's own work area and the details of your program, so add your products, labels and SDS locations to any generic content.

Do temporary and agency workers need retraining?

Plan for it if they work with the affected products at your site. We recommend agreeing in writing with the staffing agency who delivers the site-specific hazard training and who keeps the record, so nobody assumes the other side did it.

What if we have no products with newly identified hazards?

Then no additional hazard training is required for substances. Still update the written program as needed, and brief workers on small-container labels and revised SDSs so they can read the paperwork that arrives.