OSHA has issued an updated enforcement directive for its Hazard Communication Standard (HCS), providing compliance officers with revised inspection procedures and enforcement guidance following the agency's 2024 update to the standard.
While the directive is intended for OSHA enforcement personnel, it offers valuable insight for safety professionals, employers and others responsible for hazard communication programs. It reflects OSHA's ongoing implementation of HCS 2024, which aligns the U.S. standard more closely with the seventh revision of the Globally Harmonized System of Classification and Labelling of Chemicals (GHS).
Why This Matters
Hazard communication remains one of the most fundamental workplace safety requirements. Workers must understand the chemical hazards they may encounter, and employers must ensure that labels, safety data sheets (SDSs) and employee training accurately communicate those risks.
The directive also provides insight into what OSHA compliance officers will be looking for during inspections. Understanding those expectations can help safety professionals identify potential gaps and prioritize compliance efforts as their organizations transition to HCS 2024 requirements.
Key Changes for Employers and Safety Professionals
The revised Hazard Communication Standard includes updates to:
- Hazard classification criteria
- Labeling requirements
- Safety data sheet requirements
- Classification of aerosols and other chemical hazards
- Requirements for chemicals under pressure
- Trade secret provisions and hazard communication elements
The directive incorporates these changes and provides guidance to OSHA compliance officers on how to assess employer compliance during inspections.
For safety professionals, this means reviewing existing hazard communication programs to ensure they align with the revised requirements and any updated information received from chemical manufacturers and suppliers.
Important Compliance Dates
OSHA recently extended the first compliance deadline for manufacturers, importers and distributors to May 19, 2026.
Additional compliance dates affecting manufacturers, distributors and employers will phase in over the coming years as organizations complete the transition to HCS 2024 requirements. Organizations should continue working with suppliers to obtain updated labels and safety data sheets and ensure employees receive training on any new hazards or labeling elements introduced under the revised standard.
What Safety Professionals Should Do Now
Safety professionals can help their organizations prepare by:
- Reviewing written hazard communication programs
- Verifying that chemical inventories are current
- Confirming that updated safety data sheets are being received and maintained
- Evaluating workplace labeling systems for consistency with revised requirements
- Identifying any new hazard classifications that may affect employee training
- Working with suppliers and distributors to understand transition timelines
Organizations should also monitor OSHA guidance and compliance assistance materials as implementation continues.
Supporting Effective Hazard Communication
An effective hazard communication program is one of the most important tools for preventing workplace injuries and illnesses. By understanding OSHA's updated enforcement approach and preparing for the ongoing transition to HCS 2024, safety professionals can help ensure workers have the information they need to recognize chemical hazards and protect themselves on the job.
As OSHA continues implementing HCS 2024, safety professionals should take the opportunity to review their hazard communication programs, evaluate training needs and familiarize themselves with the agency's enforcement expectations. ASSP encourages members to review OSHA's enforcement directive and related compliance resources to better understand how hazard communication requirements will be evaluated during inspections.