What must be updated by November 20, 2026?

Employers must update workplace labeling, written hazard communication programs, and employee training to reflect GHS Revision 7 hazard classes (e.g., Desensitized Explosives, Aerosol Cat 3).

What demonstrates 'Good Faith' during transition?

A completed audit, training logs covering the changes, and evidence of updating the chemical inventory and SDS library. A 2012-era program will be cited.

The November 20 Deadline: Your 2026 HazCom Compliance Audit

The Drop-Dead Date

Mark it on the calendar: November 20, 2026. This is the date by which all employers—including construction contractors—must have updated their workplace labeling and hazard communication programs to align with the revisions to the Hazard Communication Standard.

The Audit Checklist

Do not wait until November. Start your audit now.

1. Written Program Review

Does your program reference GHS Revision 7?
Have you updated the "Trade Secrets" section to reflect new concentration range rules?
Is the chemical inventory current?

2. Labeling Audit

Check all secondary containers. Are they using the new hazard statements for Aerosols?
Check small containers (≤ 100ml). Are you using the new exemption correctly (Product ID + Pictogram + Signal Word)?

3. Training Validation

Have all employees been trained on the new hazard classes (Desensitized Explosives, etc.)?
Is there a sign-in sheet proving this training occurred?

4. SDS Library

Have you replaced old MSDSs with GHS SDSs?
Are you collecting the new Rev 7 SDSs from manufacturers as they are released (post-May 2026)?

The "Good Faith" Effort

If OSHA inspects you in December 2026, they will look for evidence of transition. If you are still using a 2012-era program, you will be cited. If you can show a completed audit and a training log from September 2026 covering the changes, you demonstrate "Good Faith" compliance.