HazCom 2024 training requirements: what manufacturers must do by November 20, 2026

HazCom 2024 training requirements come down to one federal deadline for most plants: by November 20, 2026, every employer must give employees any additional training needed for newly identified hazards of the substances they work with, and update workplace labels and the written hazard communication program to match. For mixtures, the same employer updates are due by May 19, 2028.

This guide is for EHS managers, plant safety leads and training coordinators in manufacturing who have to show that retraining happened, not only that it was scheduled. LMS Advisor is our own product, and it is our pick for running and evidencing that retraining: a short course with a scored quiz, QR check-in for toolbox sessions on the line, and an export of who completed what. LMS Advisor is not an OSHA-authorized trainer, supplies no ready-made HazCom course and makes no claim that using it makes you compliant.

For the wider picture of training at a plant, see our manufacturing LMS page.

What changed between HazCom 2012 and HazCom 2024?

HazCom 2024 is an update of the same standard, 29 CFR 1910.1200, not a new rule. OSHA published the final rule on May 20, 2024 (89 FR 44144), effective July 19, 2024. OSHA's rulemaking page says it aligns the standard mainly with Revision 7 of the GHS, where the 2012 version followed Revision 3.

The hazard class, trade secret and precautionary statement rows come from OSHA's 2026 HCS update questions and answers. The SDS row comes from the current text of Appendix D. OSHA has also issued two correction notices, on October 9, 2024 and January 8, 2026, listed on its corrections page. Read the current eCFR text, not a 2024 printout.

When are the HazCom 2024 compliance dates?

The employer date that matters for training on substances is November 20, 2026. OSHA moved every date back four months in a final rule published January 15, 2026, because it had not finished guidance the regulated community needed before the original January 2026 date.

Can you keep following HazCom 2012 until then?

Yes. Paragraph (j)(4) lets manufacturers, importers, distributors and employers comply with the updated standard, the version revised as of July 1, 2023, or both, until the date that applies to them. So a drum with a 2012-style label and one with a 2024-style label can sit side by side in your storeroom until November 2026, and for mixtures well past it. Your operators need to read both.

Who has to be retrained, and on what?

The rule does not order a full rerun of HazCom training for every employee. Paragraph (j)(2)(ii) requires employers to provide "any additional employee training" under (h)(3) for newly identified hazards. In plain terms: retrain the people who work with a substance whose updated SDS or label now shows a hazard they were not trained on.

The baseline training content has not changed

Paragraph (h)(1) still requires "effective information and training on hazardous chemicals in their work area" at initial assignment and whenever a new chemical hazard is introduced. Under (h)(3), training must cover at least:

1. Methods and observations that detect the presence or release of a hazardous chemical in the work area.
2. The physical, health, simple asphyxiation, combustible dust and pyrophoric gas hazards, plus hazards not otherwise classified.
3. The measures employees can take to protect themselves from those hazards.
4. The details of your program, including an explanation of shipped-container labels, your workplace labeling system and the SDS, including the order of information and how employees can obtain and use it.

Who is in scope at a typical plant

Because (h)(3)(iv) requires training to explain the labels and SDSs employees receive, we would also brief everyone else on how small-container labels and revised SDS sections look. Treat that as good practice, not a separate legal deadline. For anything you are unsure of, ask your safety counsel or OSHA's hazard communication pages.

What do the new label and SDS elements mean for plant-floor training?

Operators will meet the changes in four places: tiny containers, older stock, bulk deliveries and the SDS binder or system.

Small containers of 100 ml and 3 ml

Under (f)(12), when pull-out labels, fold-back labels or tags are not feasible, a container of 100 ml or less needs at least the product identifier, pictograms, signal word, the manufacturer's name and phone number, and a statement that the full label is on the immediate outer package. A container of 3 ml or less needs no label if any label would interfere with its normal use, but it must still bear at least the product identifier. Training point for the lab and the maintenance crib: keep small containers in the outer package that bears the complete label when they are not in use, as (f)(12)(iv)(B) requires.

Stock released for shipment

Paragraph (c) defines "released for shipment" as a chemical "packaged and labeled in the manner in which it will be distributed or sold." Under (f)(11)(i), that stock does not have to be relabeled when new hazard information arrives, but the updated label must travel with each container in each shipment. Receiving staff should know that a loose updated label in the paperwork is expected, and where it goes.

Bulk shipments

For tank trucks and rail cars, (f)(5) allows the label to be on the immediate container, travel with the shipping papers or bills of lading, or, with the receiving company's agreement, arrive electronically so that it is immediately available in print to workers on the receiving end. If your unloaders look only at the tank, show them where the label information now arrives.

Safety data sheets

The SDS keeps its 16 sections in the same order. What changed is the minimum content of four of them, as set out in the current Appendix D:

• Section 2, hazard identification: a separate entry for hazards classified under paragraph (d)(1)(ii), which covers chemical reaction products associated with known or reasonably anticipated uses.
• Section 3, composition: for mixtures, the CAS number or other unique identifier of each hazardous ingredient, and the source of the identifier when there is no CAS number or it is claimed as a trade secret. A withheld concentration now appears as one of the ranges prescribed in paragraph (i).
• Section 9, physical and chemical properties: particle characteristics are added, and several properties are merged or renamed.
• Section 11, toxicological information: interactive effects, where relevant and readily available, and a statement when alternative information was used because chemical-specific data were missing, with the method used to derive it.

Training is a short refresher on where to look, with Sections 2 and 11 pointed out, since those items are the most likely to change how a task is done.

Does OSHA require HazCom training records?

No record format is prescribed. Neither the training paragraph nor the dates paragraph of 1910.1200 tells you to keep sign-in sheets, certificates or test scores. But the rule asks for "effective" training, and the easiest way to show effectiveness after November 20, 2026 is a dated record of who was trained on which hazards, how they were trained and whether they understood it.

A record that holds up usually has the employee's name and job, the date, the topics or substances covered, the trainer or course, and a score from a short knowledge check. Keep it with the version of the written program it matched. How long to keep it is a separate question, covered in our training records retention requirements post, and the date belongs on your annual compliance training calendar.

How do you run HazCom 2024 retraining in LMS Advisor?

LMS Advisor runs the delivery and the evidence. Your EHS team owns the content, the program and the judgment of who is exposed. Here is the sequence we would use at a plant.

1. Build one short course. Start from the compliance refresher or safety briefing module template. Add a lesson per newly identified hazard group, a lesson on small-container and released-for-shipment labels, and photos of real labels from your storeroom. Upload your updated written program as a PDF lesson. See course authoring for the lesson types.
2. Add a scored quiz. Eight to ten questions tied to your own substances and labels. A quiz score is better evidence of understanding than a signature.
3. Translate it. Course and lesson translations let Spanish-speaking or other crews take the same course in their language.
4. Assign by department and shift. Use organizations, departments and groups to target operators, maintenance, receiving and the lab, with a due date before November 20, 2026 and a mandatory flag. Check the overdue report weekly, since LMS Advisor does not send reminder emails ahead of a due date.
5. Run floor sessions with QR check-in. For a pre-shift talk at the line, open an attendance session on the course and let workers scan the QR code with their phone. A supervisor can mark anyone without a phone by hand.
6. Let operators finish on the phone. The iOS and Android app plays video, PDF and reading lessons and takes the quiz, so a second-shift operator can complete it on a break. Quizzes need a connection.
7. Issue a certificate on pass. The certificate designer issues a course certificate automatically on completion, with a public verification page. Set a validity period if you run an annual HazCom refresher.
8. Export the evidence. Course and learner reports export to CSV, Excel or PDF. File the export with the program version it matches. The reporting and analytics page shows the report views.

For the step-by-step task list your team can tick off before the deadline, use our HazCom 2024 retraining checklist, which adds a sample knowledge check and a one-afternoon version for small shops.

Where does LMS Advisor stop?

• No HazCom course library. You write the content, or license a SCORM package and upload it. We do not sell courses.
• Not an OSHA-authorized trainer. LMS Advisor holds records. It does not certify, approve or audit your program.
• No SDS management or label printing. It does not print labels, or store, version or distribute safety data sheets as a system of record. Keep them in your SDS tool or binder and link to them.
• No deadline reminder emails. Use due dates, the overdue report and the never-started and stuck-in-course email automations.
• Hands-on demonstrations still need a person. If you want operators to show they can read a real label, a supervisor observes it, and the LMS records attendance.

For forklift and other powered equipment records at the same plant, see our post on forklift training records.

Frequently asked questions

What is the HazCom 2024 training deadline for employers?

November 20, 2026 for substances and May 19, 2028 for mixtures. By those dates, employers must update workplace labeling and the written program and provide any additional training for newly identified hazards, under 29 CFR 1910.1200(j) as amended on January 15, 2026.

Do all employees need full HazCom training again under HazCom 2024?

No. The rule requires additional training on newly identified hazards, so the people who must be retrained are those exposed to a substance or mixture whose hazards changed. Many employers also brief everyone on the new small-container labels and SDS revisions, because (h)(3)(iv) requires training to explain the labels and SDSs employees use.

Did OSHA extend the HazCom 2024 compliance dates?

Yes. A final rule published January 15, 2026 pushed each date back four months: May 19, 2026 and November 19, 2027 for manufacturers, importers and distributors, and November 20, 2026 and May 19, 2028 for employers.

What is the difference between HazCom 2012 and HazCom 2024?

HazCom 2024 aligns the standard mainly with GHS Revision 7 instead of Revision 3. It adds small-container label rules, flexibility for stock released for shipment and bulk shipments, prescribed concentration ranges for trade secrets, revised hazard classes and precautionary statements, and new required items in SDS Sections 2, 3, 9 and 11, such as particle characteristics in Section 9 and interactive effects in Section 11.

Does HazCom require a written test or signed training record?

No. 1910.1200 does not prescribe a test or a record form. It requires effective training, and a dated completion record with a knowledge check score is the simplest way to show that.

Can LMS Advisor deliver HazCom 2024 training?

It can deliver and record training you build. LMS Advisor runs the course, quiz, QR attendance, certificate and completion export, and learners can take the course on the web or in the mobile app. LMS Advisor is our own product, it is not an OSHA-authorized trainer, and it does not supply HazCom content or make your program compliant.

Want to see a HazCom retraining course, a quiz and the completion export built for your plant? Request a demo of LMS Advisor.