The OSHA compliance year, in plain English
Most OSHA deadlines repeat on the same calendar dates every year, so they are easy to plan around once you know them. The four that catch employers out most often are the OSHA 300A summary posting (a window, not a single day), the March 2 electronic filing through OSHA’s Injury Tracking Application, the EPCRA Tier II chemical-inventory report due March 1, and — unique to 2026 — the November 20, 2026 HazCom employer deadline created by the HCS 2024 final rule (and its January 15, 2026 four-month extension).
The calendar above tracks every one of these with a live countdown. The table below is the same data, dated and cited, so you can verify each entry against the rule itself.
Every 2026–2027 OSHA & EPCRA deadline
| Date | Deadline | Priority | Citation |
|---|---|---|---|
| January 1, 2026 | 2026 OSHA Penalty Maximums (Unchanged from 2025) | Advisory | 29 CFR 1903.15 |
| January 1, 2026 | Begin New OSHA 300 Log for 2026 | Important | 29 CFR 1904.29 |
| February 1, 2026 | OSHA 300A Posting Begins | Critical | 29 CFR 1904.32 |
| March 1, 2026 | Tier II Chemical Inventory Due (EPCRA Section 312) | Critical | 40 CFR 370.45 (EPCRA Section 312) |
| March 2, 2026 | Electronic Submission of 300A (ITA) | Critical | 29 CFR 1904.41 |
| March 2, 2026 | Electronic Submission of 300/301 (High-Hazard, incl. Construction) | Critical | 29 CFR 1904.41(a)(2) |
| April 30, 2026 | OSHA 300A Posting Period Ends | Important | 29 CFR 1904.32 |
| May 1, 2026 | Heat Season Prep (advisory — no fixed date) | Advisory | OSHA Heat NEP (CPL 03-00-024) |
| May 19, 2026 | HCS 2024 Manufacturer Deadline (Substances) | Critical | 29 CFR 1910.1200 |
| June 1, 2026 | Mid-Year HazCom Program Review | Advisory | 29 CFR 1910.1200 |
| July 1, 2026 | EPCRA Section 313 TRI Reporting (Form R / Form A) Due | Critical | 40 CFR 372.30 (EPCRA Section 313) |
| July 1, 2026 | Silica Monitoring Review (advisory — no fixed date) | Advisory | 29 CFR 1926.1153 |
| September 1, 2026 | Q3 Refresher Training — your schedule, not OSHA's | Advisory | 29 CFR 1910.1200(h) — no periodic interval in the standard |
| October 1, 2026 | Prepare for OSHA 300A Year-End | Advisory | 29 CFR 1904.32 |
| November 1, 2026 | Annual HazCom Program Review | Important | 29 CFR 1910.1200(e)(1) — program must be current; the annual cadence is practice, not a prescribed date |
| November 20, 2026 | HCS 2024 Employer Compliance Deadline (Substances) | Critical | 29 CFR 1910.1200 |
| December 1, 2026 | Year-End Recordkeeping Prep | Important | 29 CFR 1904.32 |
| January 1, 2027 | Begin New OSHA 300 Log for 2027 | Important | 29 CFR 1904.29 |
| February 1, 2027 | OSHA 300A Posting Begins | Critical | 29 CFR 1904.32 |
| March 1, 2027 | Tier II Chemical Inventory Due (EPCRA Section 312) | Critical | 40 CFR 370.45 (EPCRA Section 312) |
| March 2, 2027 | Electronic Submission of 300A (ITA) | Critical | 29 CFR 1904.41 |
| March 2, 2027 | Electronic Submission of 300/301 (High-Hazard, incl. Construction) | Critical | 29 CFR 1904.41(a)(2) |
| April 30, 2027 | OSHA 300A Posting Period Ends | Important | 29 CFR 1904.32 |
| May 1, 2027 | Heat Season Prep (advisory — no fixed date) | Advisory | OSHA Heat NEP (CPL 03-00-024) |
| June 1, 2027 | Mid-Year HazCom Program Review | Advisory | 29 CFR 1910.1200 |
| July 1, 2027 | EPCRA Section 313 TRI Reporting (Form R / Form A) Due | Critical | 40 CFR 372.30 (EPCRA Section 313) |
| July 1, 2027 | Silica Monitoring Review (advisory — no fixed date) | Advisory | 29 CFR 1926.1153 |
| September 1, 2027 | Q3 Refresher Training — your schedule, not OSHA's | Advisory | 29 CFR 1910.1200(h) — no periodic interval in the standard |
| October 1, 2027 | Prepare for OSHA 300A Year-End | Advisory | 29 CFR 1904.32 |
| November 1, 2027 | Annual HazCom Program Review | Important | 29 CFR 1910.1200(e)(1) — program must be current; the annual cadence is practice, not a prescribed date |
| November 19, 2027 | HCS 2024 Manufacturer Deadline (Mixtures) | Critical | 29 CFR 1910.1200(j)(3)(i) |
| December 1, 2027 | Year-End Recordkeeping Prep | Important | 29 CFR 1904.32 |
“Advisory” rows are best-practice reminders (e.g. mid-year program reviews), not fixed legal due dates — they are labeled as such in each description.
The four deadlines that matter most
1 · Post the OSHA 300A summary (February 1 – April 30)
Employers that must keep injury records have to post the Form 300A annual summary of the prior year’s recordable injuries and illnesses in a conspicuous place from February 1 through April 30 (29 CFR 1904.32). The summary must be certified by a company executive. The 300 Log itself runs on the calendar year: 1904.32(a) sets the review, summary and posting duties “at the end of each calendar year,” so the new Log opens onJanuary 1 — a month before the posting window. Waiting until February 1 leaves January’s recordable cases with nowhere to go.
2 · File electronically through the ITA (by March 2)
Separately from posting, certain establishments must electronically submit their injury data through OSHA’s Injury Tracking Application by March 2 (29 CFR 1904.41 (88 FR 47346, Jul 21 2023)). Who must file, and what they file, depends on size and industry:
| Who | What to submit | Citation |
|---|---|---|
| 250+ employees (not partially exempt) | 300A | 29 CFR 1904.41(a)(1)(ii) |
| 20–249 employees in an Appendix A high-hazard industry | 300A | 29 CFR 1904.41(a)(1)(i) |
| 100+ employees in an Appendix B high-hazard industry (construction: NAICS 2381 only, not the whole sector) | 300, 301, 300A | 29 CFR 1904.41(a)(2) |
The Tier B requirement (100+ employees in an Appendix B high-hazard industry; in construction, NAICS 2381 only) is the one contractors in that code miss: it requires submitting the detailed Forms 300 and 301, not just the 300A summary. The 250-employee tier (300A only) still applies beside it.
3 · File EPCRA Tier II (March 1)
This one is EPA, not OSHA. Under EPCRA §312 (40 CFR 370.45), a facility that stored a hazardous chemical above the reporting threshold at any point in the prior year must file a Tier II inventory with its State Emergency Response Commission (SERC), Local Emergency Planning Committee (LEPC), Local fire department with jurisdiction over the facility by March 1. The default threshold is 10,000 lb; for an Extremely Hazardous Substance it drops to the lower of 500 lb or the substance’s Threshold Planning Quantity.
4 · Meet the November 20, 2026 HazCom deadline
The HCS 2024 final rule aligns the Hazard Communication Standard with primarily GHS Revision 7. After the January 15, 2026 four-month extension, the in-force employer deadline for hazardous substances is November 20, 2026: by that date employers must update workplace labeling, the written HazCom program, and employee training (29 CFR 1910.1200). For mixtures, manufacturers comply by November 19, 2027 and employers by May 19, 2028.
Worked examples
A 40-person mechanical contractor. Two reasons it does not file electronically, and the second one outlasts the first: it is under 100 employees, and a mechanical contractor sits in NAICS 2382 (building equipment contractors), which is not in Appendix B at all — only 2381 is. Even at 200 employees this firm would owe the 300A under Appendix A, not the full 300 + 301 set. It still must keep a 300 Log, post the 300A from February 1 to April 30, and meet the November 20, 2026 HazCom update. If it stores more than 10,000 lb of a hazardous chemical (fuel, solvents, compressed gases), it also owes a Tier II report by March 1.
A 160-person general contractor. Now the establishment is over 100 employees in construction, so on top of posting the 300A it must electronically submit Forms 300, 301, and 300A through the ITA by March 2 (29 CFR 1904.41(a)(2)) — the detailed case-level data, not just the summary. The HazCom and (if applicable) Tier II deadlines apply the same way.
What to do next
- Subscribe once. Use “Add to my calendar (.ics)” above so every date lands in your own calendar with reminders — you will not have to remember them again.
- Confirm your ITA tier. Count employees per establishment and check whether your NAICS is in Appendix A or B; in construction only NAICS 2381 (foundation, structure and building exterior) at 100+ owes the detailed Forms 300/301; the rest of construction owes the 300A.
- Close the HazCom gap now. Relabeling, updating the written program, and retraining take time — start well before November 20, 2026.
- Check your state. State-Plan states (e.g. California, Michigan, Washington) can set different rules and dates; verify locally.
Frequently asked questions
When must the OSHA 300A Summary be posted in the workplace?
The OSHA 300A Summary must be posted from February 1 through April 30 each year in a conspicuous place where notices to employees are customarily posted (29 CFR 1904.32).
What is the electronic filing deadline for OSHA 300A data?
Establishments with 250+ employees (or 20-249 in an Appendix A high-hazard industry) must electronically submit 300A data via the ITA portal by March 2 of the year after the calendar year the forms cover (29 CFR 1904.41(c)) — for example, by March 2, 2027 for the forms covering 2026. Establishments with 100+ employees in an Appendix B high-hazard industry must also submit Forms 300 and 301 (29 CFR 1904.41). Appendix B lists exactly one construction code: 2381, Foundation, Structure and Building Exterior Contractors. Building construction (236), heavy and civil engineering (237) and the other specialty trades (2382, 2383, 2389) are not in Appendix B — those establishments owe the 300A under Appendix A, not the full 300 + 301 set.
When is the Tier II chemical inventory report due?
Under EPCRA Section 312 (40 CFR 370.45), facilities storing hazardous chemicals above threshold quantities must submit Tier II reports to the LEPC, SERC, and local fire department by March 1 each year.
Is the EPCRA TRI (Form R) report the same as the Tier II report?
No. Tier II (EPCRA Section 312, due March 1) reports the hazardous chemicals you store on site. The Toxics Release Inventory (EPCRA Section 313, Form R / Form A, due July 1 under 40 CFR 372.30) reports releases and other waste management of listed toxic chemicals for the prior calendar year. A facility can owe both, one, or neither, depending on what it stores and how much of a listed toxic chemical it manufactures, processes, or uses.
What is the November 2026 HazCom compliance deadline?
By November 20, 2026, all employers must update workplace labeling, written HazCom programs, and employee training to reflect GHS Revision 7 and the HCS 2024 Final Rule changes for hazardous substances.
Does OSHA require annual HazCom training?
No. 29 CFR 1910.1200(h)(1) requires training at initial assignment and whenever a new chemical hazard the employees have not previously been trained about is introduced into their work area. The words 'annual', 'periodic' and 'refresher' appear nowhere in paragraph (h) — this is the most repeated myth in HazCom. Many employers still refresh yearly and document attendance, which is sound practice; just do not mistake your own cadence for OSHA's requirement, and never let it replace the mandatory retraining a new hazard triggers.
Sources & verification
- 29 CFR 1904.41 (ITA electronic submission) — eCFR
- 29 CFR 1910.1200 (Hazard Communication) — eCFR
- HCS 2024 extension — Federal Register (Jan 15, 2026)
- 40 CFR Part 370 (EPCRA Tier II)
- OSHA recordkeeping (300/300A/301)
Regulatory facts verified 2026-10-05 against the eCFR, OSHA.gov, and the Federal Register. This calendar is a planning aid for federal requirements — it is not legal advice, and State-Plan states may set different dates.
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