HCS 2024 Deadlines by State Plan: Why November 20, 2026 Is the Wrong Date in Most of Them

There is no single HazCom 2024 deadline in the United States. In federal-jurisdiction states, employers must, as necessary, update any alternative workplace labeling used under (f)(6), the written program and training for newly identified hazards of substances by November 20, 2026 under 29 CFR 1910.1200(j)(2)(ii). But 22 State Plans regulate private employers under their own rules, and each writes its own schedule. We read sixteen of those rules directly rather than assuming they match. Twelve of them do not.

The most urgent finding: Washington's substances deadline was July 20, 2026 — it has already passed. If you run crews in Washington and have been planning around November 20, you are late, and the reason is a four-month federal extension that Washington did not follow.

Washington is the plainest case because its own rule prints the date. But it is not the only state that lands there. Michigan and Minnesota both adopted HCS 2024 and both pinned it before the extension existed — Michigan at July 19, 2024, Minnesota at a citation list ending October 9, 2024. The paragraph (j) each of them adopted carried the original schedule, in which the employer date for substances was that same July 20, 2026. Neither agency has published guidance resolving it, so those two are worth a phone call rather than an assumption.

At a glance: the federal employer deadline for substances is November 20, 2026. Washington is July 20, 2026 (past). Oregon is June 1, 2027. California has not adopted HCS 2024. Michigan and Minnesota both adopted the 2024 rule but pinned it before the extension, so on the face of their rules they carry the original July 20, 2026 employer date rather than November 20. The federal HazCom 2024 employer deadline for substances is November 20, 2026, but State Plans set their own compliance dates: Washington's was July 20, 2026 and has passed, Oregon's is June 1, 2027, and California has not adopted the 2024 update at all.

The federal baseline, so the comparison is honest

The HCS 2024 final rule (89 FR 44144, May 20, 2024) took effect July 19, 2024 with four phased compliance dates. A separate final rule published January 15, 2026 (FR Doc. 2026-00653) extended every one of them by four months. Those extended dates are the federal law today:

Hold on to that January 15, 2026 extension. It is the single fact that most state divergence turns on — and it is worth knowing exactly what it moved, because the dates it replaced are still live law in several states. OSHA sets them out itself:

"The compliance date in Sec. 1910.1200(j)(2)(i) is extended from January 19, 2026, until May 19, 2026; the compliance date in Sec. 1910.1200(j)(2)(ii) is extended from July 20, 2026 to November 20, 2026; the compliance date in Sec. 1910.1200(j)(3)(i) is extended from July 19, 2027 to November 19, 2027; and the compliance date in Sec. 1910.1200(j)(3)(ii) is extended from January 19, 2028 to May 19, 2028."

That first pair explains a coincidence you will notice below. July 20, 2026 is not a Washington invention — it is the original federal employer date. Washington's rule simply kept it. So does the text Michigan pinned, and the text Minnesota's citation list stops at. Three states converge on the same day for one reason: they each froze the standard before January 15, 2026, and that is the day the standard said before then.

The HCS 2024 final rule states the State Plan duty itself:

"Therefore, State Plans must adopt comparable provisions within six months of publication of the final rule." HCS 2024 final rule, 89 FR 44144 (May 20, 2024), section IX, State Plans

Read that next to the statute, because together they are the legal reason this page exists. Section 18(c)(2) of the OSH Act requires a State Plan's standards to be "at least as effective" as the federal ones (29 U.S.C. 667(c)(2)), and "at least as effective" governs the protection, not the calendar. A state may land earlier than federal or later; what it may not do is protect less. That is why Washington's earlier date and Oregon's later one are both lawful, and why neither can be guessed from the federal rule.

First: which states even have their own HazCom standard?

Before you can ask about a date you have to know which rulebook applies. OSHA publishes, plan by plan, the standards each State Plan writes for itself instead of taking the federal text. Reading all 22 full State Plans against that list gives a clean split — and it is the split almost every "HazCom deadline" article skips.

Ten of the 22 write their own hazard communication rule. Twelve take the federal text.

* Three of these are right-to-know layers on top of the federal text, not replacements — Iowa's "Hazardous Chemical Risks Right to Know", Minnesota's "Hazardous Substances" / Employee Right to Know, and Tennessee's chapter 0800-01-09, which states in terms that "Employers are required to comply with 29 CFR 1910.1200(f)". Each means a second rulebook in that state, not a different HazCom standard.

New Mexico and Washington both carry a unique hazard communication standard across all three sectors — general industry, construction and agriculture — so in those states the sector you work in does not change the answer.

But "takes the federal text" does not mean "federal dates." That is the trap, and it is the second axis.

Second: how the state adopts changes

A plan that uses the federal text still has to pull each federal amendment across, and there are two ways to do it:

• Dynamic — the rule reads "as amended", so a federal change flows through on its own.
• Static — the rule names specific Federal Register notices by volume, page and date. The state is bound to the text exactly as it read in those notices, and a later federal amendment does nothing until the state adds it to the list.

That distinction is why a state can have genuinely adopted HCS 2024 and still be working from the pre-extension dates. The January 15, 2026 extension is a separate Federal Register notice; a static adopter does not get it until it says so.

What the rules actually say, state by state

Each row below was read in the state's own regulation. Sources are linked at the end.

Six different mechanisms across twenty jurisdictions. Tennessee is a shape of its own again: chapter 0800-01-09 requires compliance with federal 1910.1200(f) and adds a workplace chemical list, fire-department placarding and public-disclosure duties on top of it. Alaska, Nevada and New Mexico each maintain a hazard communication standard of their own — which is exactly why each has to be read rather than assumed, and reading them cuts both ways: Alaska and New Mexico point straight back at the federal text, while in Nevada the state's own rule is the one enforced.

Mechanism 1 — the state wrote its own schedule

Washington: four months early, and the first date has passed

WAC 296-901-14020, as amended by WSR 26-02-011 — filed December 30, 2025, effective February 1, 2026 — reads:

"Employers, chemical manufacturers, importers, and distributors evaluating substances must be in compliance with all provisions of this section no later than July 20, 2026. […] For mixtures, chemical manufacturers, importers, and distributors must comply no later than July 19, 2027. Employers must update labeling and programs no later than January 19, 2028."

Those are the original federal dates — the ones that existed before the January 15, 2026 extension. Washington filed its rule on December 30, 2025, roughly two weeks before OSHA published the extension, and has not amended the chapter since; the chapter's own "last update" stamp still reads 12/30/25. So Washington sits four months ahead of federal on three of the four dates — with one reversal worth knowing:

Note the other Washington wrinkle: its substances date is a single date for everyone — employers and the supply chain together — where the federal rule splits manufacturers (May 19, 2026) from employers (November 20, 2026). A Washington employer never got the six-month cushion federal employers got after their suppliers relabeled.

Full state detail: Washington's HazCom rule, chapter by chapter.

Oregon: six months later, and it never adopted (j) at all

Oregon states its position in the rulemaking record rather than leaving it to be inferred. Its adoption notice states that the revised dates are "in lieu of adopting the January 15, 2026, Federal Register notice" — the federal extension — and that Oregon OSHA "did not adopt 29 CFR 1910.1200(j), Effective Dates". The rule prescribes five dates of its own: (j)(1) July 1, 2026 · (j)(2)(i) January 1, 2027 · (j)(2)(ii) June 1, 2027 · (j)(3)(i) January 1, 2028 · (j)(3)(ii) June 1, 2028.

Oregon took the opposite path. It did not adopt 29 CFR 1910.1200(j) — the paragraph that carries the federal compliance dates — and wrote its own schedule at OAR 437-002-0376, giving employers until June 1, 2027 for substances. That is roughly six months later than federal.

An Oregon employer reading a federal-dated compliance calendar is not late; they are early, which costs money rather than citations. The reverse mistake — a multi-state contractor applying Oregon's June 2027 date to a Washington jobsite — is the expensive one.

Full state detail: Oregon's four HazCom dates and why they differ.

California: the 2024 rule has not arrived

California enforces its own standard, Title 8 §5194, and it has not been updated for HCS 2024. Three things establish that, all visible in the published regulation:

• Its transition paragraph still reads "by December 1, 2013" for training on the new label elements and SDS format, and "no later than June 1, 2015" for full compliance. Those are the HCS 2012 dates.
• The most recent entry in its rulemaking history is a change without regulatory effect filed in 2016.
• The regulation contains none of what the 2024 rule added — no desensitized explosives hazard class, no chemicals under pressure, no non-flammable aerosol Category 3.

Cal/OSHA must eventually adopt a standard at least as effective as the revised federal rule. Until it does, §5194 as published is what Cal/OSHA inspects against — which means a California employer has no state HazCom 2024 deadline to miss yet, and also no state authority for the new classes appearing on supplier labels shipped into California under federal rules.

Full state detail: California §5194 and what it adds beyond federal.

Mechanism 2 — static incorporation by reference

This is the trap that hides in plain sight, and it can catch a state that has genuinely adopted HCS 2024.

There are two ways a state plan can adopt a federal standard by reference:

• Dynamic — the rule says something like "as amended", so later federal changes flow through automatically.
• Static — the rule adopts specific Federal Register notices by volume, page numbers and date. The state is bound to the text exactly as it read in those notices. A later federal amendment does not apply until the state adds it to the list.

Minnesota Rules 5205.0010 is static. It incorporates federal standards by enumerating Federal Register citations one by one, and its HazCom lineage runs from the 1983 original through to:

"Federal Register, Volume 89, No. 98, pages 44144-44461, dated May 20, 2024: 'Hazard Communication Standard.'" "Federal Register, Volume 89, No. 196, pages 81829-81836, dated October 9, 2024: 'Hazard Communication Standard.'"

So Minnesota has adopted HCS 2024 — the May 2024 final rule plus the October 2024 technical corrections. But the list contains no citation dated 2025 or 2026 anywhere in the rule, on any subject. The January 15, 2026 extension is not in it.

What follows from that. The federal text Minnesota incorporated is the text as it read on October 9, 2024 — and that text carried the original compliance dates, not the extended ones. On the face of the rule, then, Minnesota is working from the pre-extension schedule. Minnesota DLI has not published guidance on the point, so confirm it with the agency before you plan around November 2026 — and make that call now rather than in the autumn, because the version that costs you money is the one where Minnesota's date has already run.

Michigan: its own Parts, pinned to fixed dates

Michigan runs hazard communication through Parts 42, 92 and 430 rather than a single standard, and its adoption rule names dates rather than tracking the federal text as amended. R 408.19202(1)(a) adopts "29 CFR 1910.1200 'Hazard Communication,' July 19, 2024"; (1)(b) adopts the same standard as of February 8, 2013. The rules took effect August 12, 2025 (2025 MR 15).

July 19, 2024 is the effective date of the HCS 2024 final rule, so Michigan does have the 2024 standard. But every date Michigan names precedes the January 15, 2026 extension — which puts Michigan in the same category as Minnesota, Arizona and Utah rather than on the federal calendar.

That has a consequence worth stating plainly, because it is easy to miss behind the word "2024". The paragraph (j) Michigan pinned is the one published on May 20, 2024, and it carried the original compliance dates. On the face of the rule, then, a Michigan employer's substances deadline was July 20, 2026 — the same date as Washington's, and equally past — not November 20, 2026. MIOSHA has published no guidance resolving it, so settle the point with the agency rather than on this reading alone.

Virginia: federal-identical text, on a recorded amendment clock

Virginia adopts the federal general industry standards identically under 16VAC25-90, and the code publishes an amendment date for each CFR section it takes. The entry for 1910.1200 — and for Appendices A, B, C and D alongside it — records amendments effective November 20, 2024 and July 30, 2025. Both sit after the HCS 2024 final rule, so Virginia has the 2024 standard.

What matters for a date is the second half of that record: Virginia's most recent recorded HazCom amendment predates the January 15, 2026 federal extension. A Virginia contractor should confirm the operative date with DOLI rather than reading it off the federal calendar.

Arizona: frozen four years before the rule was written

Arizona is the clearest case on this page, because its rule says so outright. Ariz. Admin. Code R20-5-602 adopts the federal general industry standards "as published in 29 CFR 1910, with amendments as of July 14, 2020", and then closes the door explicitly:

"This incorporation by reference does not include amendments or editions to 29 CFR 1910 published after July 14, 2020."

HCS 2024 was published May 20, 2024 — nearly four years after that cut-off. The section's own most recent amendment took effect September 4, 2022, and still carries the 2020 date. On the face of the rule, the hazard communication standard Arizona incorporates is the pre-2024 one. An Arizona employer planning to a federal HazCom date should confirm the operative rule with ADOSH first.

Utah: a dated CFR edition, and the trap it used to set

Utah does the same thing with a different instrument. Utah Admin. Code R614-1-4(A)(3) incorporates "29 CFR 1910.6 and 1910.21 through the end of part 1910, of the July 1, 2025, edition" — a fixed annual edition of the Code of Federal Regulations rather than an "as amended" reference — and names three Federal Register notices one by one: the January 8, 2026 "Hazard Communication Standard; Corrections" (91 FR 562–598), the January 15, 2026 "Hazard Communication Standard" notice (91 FR 1695–1696, the date extension) and the February 13, 2026 corrections (91 FR 6760). The rule page on the Utah Division of Administrative Rules shows an effective date of May 22, 2026. Naming the January 15 notice puts Utah on the federal HCS 2024 dates.

It was not always so, and the earlier wording is why this section exists. Until that amendment R614-1-4 named the July 1, 2024 edition, and "July 1, 2024" reads like a current date. It is not: the annual edition of Title 29 closes on July 1, HCS 2024 took effect on July 19, 2024 — eighteen days later — so that edition of 1910.1200 went to print carrying the 2012 hazard communication text. You can see it in the edition itself: the section's source citation closes at "78 FR 9313, Feb. 8, 2013", and directly beneath it the edition prints an editor's note — "Amendments to § 1910.1200 were published at 89 FR 44356, May 20, 2024, effective July 19, 2024" — which is the CFR's way of saying published, but not in the text you are reading.

A rule that names an edition therefore says nothing by its date alone. What settles it is the notices the rule lists next to the edition, because a notice can carry in what the edition left out. Utah's current rule lists them, and that is the part to check on a state's page before relying on an edition date.

North Carolina does it in a third form: 13 NCAC 07F .0101, as amended, incorporates 29 CFR 1910 "promulgated as of June 1, 2022; July 1, 2024; October 10, 2024; and exclusive of subsequent amendments". That last date falls just after the October 9, 2024 HCS corrections, so North Carolina carries the 2024 standard as corrected — and, by the rule's own terms, nothing published after it.

The remaining five, and what can be said about them

Nevada, Maryland, South Carolina, Vermont and Wyoming publish their rules on hosts outside our reach, so what follows comes from OSHA's own record of each plan rather than from the state's regulation — which is enough to tell you which rulebook applies, and not enough to give you a date.

• Nevada — OSHA lists hazard communication among Nevada's unique general-industry standards, alongside safety programs, cranes, asbestos, explosives, ammonium perchlorate, photovoltaic installation and sanitation. The Nevada rule is the one enforced; the federal text is not a safe substitute.
• Maryland — "MOSH has adopted all federal OSHA standards ... which are incorporated by reference." Maryland writes its own rules in ten other areas; hazard communication is not one. If you go looking, note that COMAR 09.12.21.02 and the 2026 "as amended" change in the Maryland Register both concern Part 1904 recordkeeping, not Part 1910.
• South Carolina — "SC OSHA has identically adopted OSHA standards and regulations", published as Code of Regulations chapter 71, article 1, subarticle 6.
• Vermont — rules built chapter by chapter, each incorporating one federal standard. Hazard communication has no Vermont chapter; the only two unique standards are PELs and lineworker safety.
• Wyoming — adopts identically "except for Subpart A of 29 CFR Part 1910 and Subparts A and B of 29 CFR Part 1926, which have been reworded to reflect the Wyoming Occupational Health and Safety Act." Subpart A is scope and definitions, so the rewording does not reach Subpart Z.

Puerto Rico: identical adoption, stated in the plan itself

Puerto Rico is the simplest entry here. OSHA's own state-plan page records, in Spanish, that "OSHA Puerto Rico ha adoptado idénticamente todas las normas y reglamentos de OSHA Federal" — Puerto Rico has identically adopted all federal OSHA standards and regulations. Its own promulgated rules cover workplace violence, boilers and pressure vessels, and elevators; hazard communication is not among them.

That is OSHA's characterization of the plan rather than a quotation from a Puerto Rico regulation, so read it as the mechanism rather than as a compliance date.

Hawaii: the oldest edition on this page

Hawaii uses the dated-edition instrument, and names the earliest edition of any state read here. HAR 12-60-50(a) makes "Title 29, Part 1910 of the Code of Federal Regulations, 2017 Edition published as of July 1, 2017 ... a part of this chapter except as provided in subsections (b) through (d)." Those subsections add Hawaii-specific definitions, noise limits and toxic-substance requirements — none of them touches 1910.1200. The chapter was compiled October 27, 2018.

Here is the part that surprises people, and it is what the Utah section above was building towards. For hazard communication, Hawaii's 2017 edition and the July 2024 edition (the one Utah named until its May 2026 amendment) are the same text. Both print 1910.1200 with its source citation closing at "78 FR 9313, Feb. 8, 2013", because the standard was not amended once between February 2013 and May 2024. Seven years separate the two editions and not a comma of HazCom separates them.

So "which edition does my state name?" is the wrong first question. For this standard, every annual edition from 2013 through 2024 says the same thing, and the only line that matters is whether the state picked up the May 20, 2024 notice — by naming it, by an "as amended" reference, or by adopting an edition from 2025 onward. An edition date near the present is not evidence that it did.

A word of warning if you go looking yourself: an older PDF of the same chapter is still in circulation naming the 2012 edition. The compiled 2018 version is the one to read — though for hazard communication the gap between them is narrower than five years sounds. The 2012 edition already carries the GHS overhaul: pictograms, signal words, and the December 1, 2013 transition date. Its source citation simply stops one amendment earlier, at 77 FR 17785 (March 26, 2012), without the technical corrections published at 78 FR 9313 (February 8, 2013).

Indiana: a bulletin per notice, with its own clock

Indiana runs a third mechanism again, and it is the most explicit of all because the state publishes a numbered bulletin for each federal notice it takes. Under IC 22-8-1.1-16.2, a federal standard may be enforced by the Indiana Department of Labor "not earlier than sixty (60) days after the final standard by federal OSHA becomes effective".

So HazCom arrived in Indiana in two pieces:

Indiana therefore has HCS 2024 as corrected, arriving roughly four to six months after each federal date. And because the mechanism is one bulletin per notice, any further federal amendment needs a bulletin of its own before it reaches an Indiana employer.

Kentucky: dated notices for other standards, an undated reference for HazCom

Kentucky is the state where reading the right chapter matters most, because it does both things at once — and not for the same standards.

Where it names a date, it is precise about it. 803 KAR 2:403, the construction health chapter, adopts "29 C.F.R. 1926.50 through 1926.66" and then separately takes "the revisions to 29 C.F.R 1926.55 as published in the January 9, 2017 Federal Register" and the May 14, 2019 amendments to 1926.50, 1926.55 and 1926.64. Those are PEL and process-safety sections.

Hazard communication is not one of them. It arrives inside the undated range instead: 1926.59 is the construction hazard communication section, and it sits between 1926.50 and 1926.66. General industry works the same way — 803 KAR 2:320 Section 6 says "general industry shall comply with 29 C.F.R. Subpart Z, Toxic and Hazardous Substances, published by the Office of the Federal Register, National Archives and Records Administration", naming no date and no edition, and 1910.1200 sits in Subpart Z.

So Kentucky is not a named-notice adopter for HazCom the way Minnesota and Iowa are. What it gives you instead is the chapter's own amendment date: the general-industry chapter was last amended effective July 1, 2025, the construction one effective November 10, 2022. Neither names a Federal Register notice for 1910.1200 or 1926.59, so the January 15, 2026 extension appears nowhere in Kentucky's own text — the practical caution is the same as everywhere else on this page.

Iowa: an enumerated list that runs through HCS 2024

Iowa enumerates its federal notices the way Minnesota does. Iowa Admin. Code r. 481—210.4(88) adopts 29 CFR Part 1910 "as published at 37 Fed. Reg. 22102 to 22324 (October 18, 1972) and as amended at:", followed by a dated list. The last two entries are 89 Fed. Reg. 44144 (May 20, 2024), the HCS 2024 final rule, and 89 Fed. Reg. 81829 (October 9, 2024), OSHA's correction notice. Two rulemakings put them there: ARC 8411C, effective November 6, 2024, and ARC 9069C, effective March 12, 2025. The rule was numbered 875-10.20 when it was adopted and moved to Inspections and Appeals chapter 210 in the IAC supplement of July 9, 2025; the January 15, 2026 extension is not in the list.

Iowa also keeps a separate "Hazardous Chemical Risks Right to Know" standard, so there are two rulebooks to read here. The adoption rule for every State Plan is mapped in State Plan HazCom Rule Numbers.

Alaska: the clearest case of a rule that flows through

Most of the states above freeze the federal text at some point. Alaska does the opposite, and it says so in the plainest words of any rule on this page. 8 AAC 61.1010(b) makes "29 C.F.R. ... 1910.1024 - 1910.1450, as amended" Alaska standards — a range that contains 1910.1200 — and 8 AAC 61.1110 refers again to "29 C.F.R 1910.1200, as amended".

Those two words do the work. Because Alaska incorporates by amendment rather than by a named edition or a listed Federal Register notice, later federal changes reach Alaska employers without any state action — including the January 15, 2026 extension. An Alaska employer is on the federal calendar.

Alaska then adds a duty with no federal counterpart: a physical agent data sheet for each physical agent present in the workplace — heat and cold stress, hand-arm vibration, ionizing radiation, lasers, noise, RF and microwave, ultraviolet. It is the hazard-communication idea applied to physical rather than chemical agents, and a federal-only program will not have it.

Alaska is the clearest of these, not the only one. Three other rules read for this page also point at the federal text without pinning it: New Mexico incorporates 29 CFR Part 1910 naming no edition and no notice, Kentucky reaches HazCom through undated references to Subpart Z and to 1926.50–1926.66, and Tennessee requires compliance with federal 1910.1200(f) outright and layers its own duties on top. Four of the sixteen, then, land on the federal calendar — and in three of those four you only discover it by noticing what the rule doesn't say.

For the other twelve the practical point is the reverse, and it is the same in each: a federal amendment published after the named date does not reach the employer until the state moves its reference. Nothing about that is unusual or improper — it is simply how static incorporation works, and it is invisible unless you read the adoption rule rather than the standard.

What this costs a multi-state contractor

Take a subcontractor with crews in Washington, Oregon, California and Michigan — an ordinary multi-state footprint. Four jurisdictions, four regimes:

Michigan is the row that deserves a second look, and it is the reason this table is not a schedule you can lift. MIOSHA adopted 29 CFR 1910.1200 as it stood on July 19, 2024. Paragraph (j) of that text carried the original dates, and the four-month extension came eighteen months later, in a notice Michigan's rule does not name. Read literally, a Michigan employer's substances date was July 20, 2026 — not November 20 — and it has gone. MIOSHA has published no guidance resolving the point, so confirm it with the agency rather than planning around either date on your own reading.

There is no version of "the HazCom deadline" that is correct for that company. And the failure mode is asymmetric: being early costs relabeling effort, being late costs a citation. That asymmetry is the whole practical lesson.

The operational answer is simple even though the law is not. Run your relabeling, program update and retraining to the earliest date across your footprint, then document the state-by-state basis for the schedule. An inspector in any of those states then sees a deliberate multi-jurisdiction plan rather than a federal default that happened to be wrong locally.

How to check your own state in ten minutes

Three questions, in order. Each one has caught a real state.

1. Does my state plan have its own HazCom rule, and has it been updated for HCS 2024? Look for what the 2024 rule added — the desensitized explosives hazard class, chemicals under pressure, and the non-flammable aerosol Category 3. If none of them appears, the rule predates HCS 2024, as California's does.
2. If it has been updated, did it copy the federal dates or write its own? Oregon and Washington wrote their own, in opposite directions.
3. Did it pick up the four-month extension of January 15, 2026? If your state adopts federal notices by enumerated citation, look for a 2026 entry in the list. If there is none, the state is bound to the pre-extension text — that is what Minnesota's rule shows on its face, and Washington's own-schedule version of the same gap is what moved its deadline into the past.

If all three answers point at federal, you are on November 20, 2026. If any one of them does not, you are not.

What does not change, in any state

Whatever your date, the work is identical, because "at least as effective" governs the substance everywhere:

• Supplier labels and SDSs arrive reclassified to GHS Revision 7. You do not classify — the manufacturer does (1910.1200(d) is their duty); you read SDS Section 2 and act on it.
• Workplace/secondary container labels follow (f)(6) and its two options, at any container size. There is no volume cutoff for containers you fill in-house — see GHS label requirements.
• Training is due when a new chemical hazard is introduced into the work area under (h)(1) — and the new hazard classes are exactly that trigger. It is not an annual cycle; see how often OSHA training is really required.
• The written program must describe how you meet the (f), (g) and (h) criteria — and it has to be current, which a reclassified inventory makes it not.

Sources and how each row was verified

Every state row above comes from the state's own published regulation, read on August 7, 2026:

• Federal — 29 CFR 1910.1200, paragraph (j); extension per FR Doc. 2026-00653, January 15, 2026.
• Washington — WAC 296-901-14020, as amended by WSR 26-02-011 (filed December 30, 2025, effective February 1, 2026); chapter last updated 12/30/25 with no pending amendment shown.
• California — 8 CCR §5194, including its subsection (j) transition dates and its rulemaking history.
• Minnesota — Minn. R. 5205.0010, the full enumerated Federal Register list.
• Oregon — OAR 437-002-0376, quoted from Oregon OSHA's adopted-rule notice AO 1-2026; see also our Oregon state-plan page.
• Michigan — MIOSHA Part 92, R 408.19201–19204; effective date confirmed against the MIOSHA standards index on michigan.gov.
• Virginia — 16VAC25-90, the Federal Identical General Industry Standards table, entry for 1910.1200.
• Arizona — Ariz. Admin. Code R20-5-602, Arizona Secretary of State, Title 20, chapter 5 (the site refuses automated reads, so this row was not re-read on October 6, 2026).
• Utah — Utah Admin. Code R614-1-4, Utah Division of Administrative Rules, current rule effective May 22, 2026, read October 6, 2026.
• What a dated CFR edition actually contains — the annual editions themselves, on govinfo: 1910.1200, 2024 edition (source citation closing at 78 FR 9313, and the effective-date note for 89 FR 44356) and 1910.1200, 2017 edition.
• North Carolina — 13 NCAC 07F .0101, as amended (NC OAH final revised rule).
• Puerto Rico — OSHA Puerto Rico State Plan.
• Hawaii — HAR 12-60, General Safety and Health Requirements, compiled 10/27/2018.
• Indiana — IOSSC Adoption by Reference Bulletin #24-01 and Bulletin #24-02.
• Kentucky — 803 KAR 2:320 and 803 KAR 2:403.
• Iowa — Iowa Admin. Code r. 481—210.4(88), official chapter PDF (IAC supplement of July 9, 2025).
• Alaska — 8 AAC 61.1010 and 8 AAC 61.1110, Alaska Legislature, Administrative Code, read October 6, 2026.
• New Mexico — 11.5.2.9 NMAC, New Mexico State Records Center & Archives.
• Tennessee — Tenn. Comp. R. & Regs. 0800-01-09, Hazardous Chemical Right to Know (revision published November 2014).
• State Plan framework — OSHA State Plans; the quoted duty is from OSHA's 2026 HCS questions and answers, citing OSH Act section 18(c), 29 U.S.C. 667(c)(2).

Every date above is quoted from the rule that carries it, with its citation and the date it was read. That is why Washington's July 20, 2026 appears here and almost nowhere else. More jurisdictions are added as their rules are read, on the same terms — and the three questions above settle any state in ten minutes.

Where to go next

• The full picture of which plans regulate private employers: the 29 OSHA-approved State Plans and the public-sector-only trap.
• Your federal date by role and chemical type: HCS 2024 deadline lookup.
• The relabeling work itself: HCS 2024 relabel action planner and the GHS Labels hub.
• Penalty exposure if you miss it, by state: OSHA penalties by state.

Not legal advice. State plans amend their rules on their own schedules; verify against your state agency's current published rule before setting a compliance date.