OSHA Hazard Communication Standard 2024 Update | What Employers Need to Know

OSHA Hazard Communication Standard Updates: 2012 vs. 2024

To understand the 2024 update, it helps to put it in context.

The 2012 HazCom update was a major overhaul. OSHA aligned the standard with the Globally Harmonized System (GHS), introducing:

• Pictograms
• Standardized label elements
• The 16-section Safety Data Sheet (SDS) format

Most employers remember this update because it fundamentally changed how chemical hazards were communicated.

The 2024 update, by comparison, is much narrower. It aligns OSHA’s standard with a newer version of GHS, but it does not reinvent the hazard communication system.

What Did NOT Change in the 2024 HazCom Update

Let us clear up one of the biggest misconceptions first.

The 2024 update did not:

• Add new types of label elements
• Add new pictograms
• Change the SDS format
• Require retraining employees on how to read labels or SDSs

If your employees were trained after the 2012 update, they already understand:

• Product identifiers
• Signal words
• Hazard statements
• Precautionary statements
• Pictograms
• How to use an SDS

All of that still applies.

What DID Change in the OSHA HazCom 2024 Rule

The 2024 update focuses on how certain hazards are classified, not on changing how hazards are communicated.

OSHA adopted updated GHS classification criteria for specific hazards, including:

• Flammable gases (revised categories)
• Aerosols
• Chemicals under pressure
• Certain physical and health hazard classifications

Because of these changes, some chemicals may now be classified differently than before, even though the product itself has not changed.

That distinction is critical for employers.

When Employee Training Is Required Under the 2024 HazCom Update

Here is the most important compliance takeaway:

Additional training is required only when employees are exposed to new or different hazard information.

Training is triggered by changed hazards, not by the existence of a new OSHA rule.

Examples of when training is required:

• A chemical now has a new hazard classification
• A product label includes a new pictogram or hazard statement
• An SDS identifies hazards employees were not previously trained on

Examples of when training is not required:

• Employees already understand labels and SDSs
• No hazard classifications for chemicals in your workplace have changed
• The update only affects manufacturers or distributors, not end users

This is targeted training, not blanket retraining.

2026 HazCom Training Deadline: Who Needs It

OSHA has set a new compliance deadline of 2026 for training employees on updated hazard classifications.

• This does not apply to every workplace.
• It only affects employees who handle chemicals that are newly classified or have revised hazard information under the 2024 rule.
• Employers must provide training by July 20, 2026 for newly classified substances and by January 19, 2028 for mixtures containing these substances.

For most employers, this means only a small subset of employees will need additional training, not your entire workforce.

Label and Pictogram Changes Explained, Including HNOCs

Some employers have heard that label requirements or pictograms changed in 2024, particularly regarding the exclamation mark pictogram and Hazards Not Otherwise Classified (HNOCs).

Here is what actually happened:

• The exclamation mark pictogram is not new
• OSHA had already allowed its use for certain HNOC hazards through guidance
• The 2024 update formalized that allowance in the regulatory text

For employees, this does not introduce a new symbol or concept. It just means that some hazards may now appear more clearly or consistently on labels.

Again, the training impact is about how labels apply to specific chemicals, not learning a new labeling system.

Do Employers Need to Retrain All Employees on HazCom?

For most employers, the answer is no.

You do not need to:

• Redo full Hazard Communication training
• Re-explain pictograms employees already understand
• Conduct training simply because OSHA issued an update

You do need to:

• Review updated SDSs as they are received
• Identify chemicals that now have revised hazard classifications
• Provide focused training to employees who handle these chemicals before the 2026 deadline

This approach is fully consistent with long-standing HazCom training requirements.

OSHA HazCom 2024 Update: Bottom Line for Employers

The 2024 Hazard Communication update means:

• The communication system stays the same
• Labels and SDSs work the same way
• Pictograms did not change
• Some hazard classifications may be different
• A small subset of employees may need training by 2026

Employers should focus on whether the chemicals they use now carry different hazard information, not on the fact that OSHA updated the rule.

If you already have a solid Hazard Communication program, this update is more about review, verification, and targeted training than rebuilding your program from scratch.