Compliance

First HazCom Compliance Date Just Around the Corner

November 5, 2025

OSHA's updated Hazard Communication (HazCom) standard took effect on July 19, 2024, with staggered compliance dates extending into 2028. The first critical compliance deadline is approaching fast. Sky Transport Solutions helps trucking companies and other employers understand these new requirements and ensure timely compliance.

January 19, 2026: First Compliance Deadline

By January 19, 2026, manufacturers, importers, and distributors evaluating substances must be in full compliance with all modified provisions of 29 CFR 1910.1200. These entities must reclassify aerosols, desensitized explosives, and flammable gases under the new criteria outlined in Appendix B to 1910.1200 and make corresponding updates to their safety data sheets (SDSs) and labels.

Required Updates for Manufacturers, Importers, and Distributors

These entities must comply with the following changes, as applicable:

  • Labels for packages released for shipment (1910.1200(f)(11))
  • Labels for bulk shipments (1910.1200(f)(5)(ii))
  • Labels for small containers (1910.1200(f)(12))
  • SDS subsections (Appendix D to 1910.1200)
  • Trade secrets (1910.1200(i))

What This Means for Downstream Users

Downstream users of substances that are aerosols, desensitized explosives, or flammable gases will begin to see updated SDSs and labels on shipped containers of hazardous chemicals (if they haven't already). Trucking companies that handle or transport these materials should be prepared to receive and work with the updated documentation.

July 20, 2026: Employer Compliance Deadline

By July 20, 2026, impacted employers must, as necessary:

  • Update any alternative (in-house) labeling
  • Update their HazCom training program
  • Provide additional employee training for newly identified physical, health, or other hazards covered

OSHA notes that because the updated HazCom standard contains only limited revisions of the hazard classification rules, it does not anticipate that most employers will need to complete these additional requirements. However, Sky Transport Solutions recommends that trucking companies review their current HazCom programs to determine if updates are needed.

Key Takeaway from Sky Transport Solutions

The first HazCom compliance deadline is January 19, 2026, affecting manufacturers, importers, and distributors. Employers have until July 20, 2026 to update their programs and training. Sky Transport Solutions can help trucking companies assess their HazCom compliance needs and ensure they meet all applicable deadlines.

How Sky Transport Solutions Can Help

At Sky Transport Solutions, we understand that HazCom compliance is essential for maintaining workplace safety and regulatory compliance. Our team can assist trucking companies with:

  • Reviewing current HazCom programs and identifying necessary updates
  • Updating in-house labeling systems to meet new requirements
  • Developing and updating HazCom training programs
  • Ensuring compliance with all applicable deadlines
  • Managing documentation and recordkeeping requirements

Contact Sky Transport Solutions today to ensure your trucking business is prepared for the upcoming HazCom compliance deadlines and maintains full regulatory compliance.

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