Is FY2026 the Last Clean Year for HazCom Comparisons?

Each year, the Occupational Health and Safety Administration (OSHA) lists its most cited safety rules. The Hazard communication standard (HazCom) almost always sits near the top. In 2025, it secured the No. 2 position on the list, with 2,546 violations recorded. In 2024, it held the same position, with 2,888 violations. These updates are not just numbers for safety managers. By comparing this year’s violation count with the previous year’s, safety managers can identify compliance trends and decide where to spend their training budget.

Making this type of comparison won’t be as easy anymore. OSHA’s fiscal year 2026 runs from October 1, 2025 through September 30, 2026. It may be the last year that HazCom citation counts can be measured against a clean, stable baseline. Fiscal year 2027 comes with a new set of rules.

The Rules Behind the HazCom Standard Transition Deadline

In 2024, OSHA updated the Hazard Communication Standard (29 CFR 1910.1200). The update brought the standard in line with the seventh revision of the Globally Harmonized System of Classification and Labelling of Chemicals, usually called GHS Revision 7. It is an international system built by the United Nations that sets shared rules for how chemical hazards get classified, labeled, and written up.

OSHA’s 2024 update changed some of the rules that shape a safety data sheet (SDS), which is a document that informs about chemical hazards, safe handling steps, and emergency instructions. OSHA didn’t issue a single deadline to embrace the changes. Rather, gave companies a longer, staged transition. During this period, an organization may follow the older 2012 version of the standard, the newer 2024 version, or a mix of both.

To facilitate understanding and help implement the changes, OSHA extended every important deadline. Earlier, the chemical manufacturers, importers, and distributors had until Jan 19, 2026, to evaluate certain substances. The updated deadline was May 19, 2026. Employers can now update their own workplace labels, make changes to hazard communication programs, and provide required employee training until Nov 20, 2026.

There are two other compliance deadline updates. The latest deadline for manufacturers and distributors to comply with the updates related to evaluating mixtures is Nov 19, 2027. Employers can provide all relevant employee training by Nov 19, 2028.

The employer deadline of November 20, 2026 falls after fiscal 2026 ends. Because of that timing, almost every HazCom citation written during fiscal 2026 involves a workplace that was still allowed to use the old standard, the new standard, or a mix of both. Fiscal year 2027 works differently. Once the employer deadline for substances has passed, an inspector who finds an old written program, an outdated label, or a missing training record is not looking at a company that simply has not gotten to it yet. The inspector is checking a legal requirement that has now come due.

How Is the HazCom Standard Transition Tracking?

There’s no real-time way to find out how close the industry is to the November 2026 line. OSHA doesn’t publish a running count of how many substance SDSs have been reissued to the new standard.

A survey, based on an online SDS library, reveals that some manufacturers have already reissued SDSs to reflect GHS Revision 7 classification changes since the May 2026 manufacturer deadline took effect.

If updates continue at this pace, many SDSs may still carry outdated classifications by the time the employer deadline hits in November and into fiscal year 2027.

Where Do Most OSHA HazCom Citations Happen?

1. Outdated Written Programs:

Organizations handling chemical products must have a written plan. They must include a list of all in-house chemical products. Also, they need to mention how they handle labels, safety data sheets, and employee training. An inspector cites this if the plan doesn’t exist or if it describes a workplace that no longer matches reality. For instance: a plan written years ago that talks about a file that the company no longer uses.

2. Safety Data Sheets (SDSs):

A company must keep one SDS for every harmful chemical product they have. Each employee of the company must be able to read and understand an SDS, and all these documents must be easily accessible. Organizations get a citation if inspectors find outdated, invalid, or not easily accessible SDSs.

3. Mandatory Employee Training:

All workers must receive training on how to handle chemical products before they receive their first assignment. Employers must maintain training records of current employees as inspectors review all such documents. 

4. Proper Chemical Labeling:

During HazCom inspections, an inspector compares all container labels against the existing SDSs. A label that doesn’t match a chemical’s current classification and SDS is treated the same as a missing or incorrect label. Naturally, labels that don’t keep pace become citable.

What HazCom Changes Mean for FY27

Companies are not breaking any rules if they are still using old standards for substances for now. The new standard is not yet compulsory. In FY27, that changes when substances must comply.

In FY2027, the citation count doesn’t tell the complete story. What is more important is how fast companies embrace the changes, update their written programs, SDSs, and train employees before the deadlines arrive.

Contributing Author: Sanghita Ghosh

Sanghita Ghosh is a B2B SaaS content writer at CloudSDS, where she creates content focused on EHS, chemical compliance, and hazard communication topics for safety professionals navigating complex regulatory requirements. Connect with her on LinkedIn: https://www.linkedin.com/in/sanghita-ghosh-a56294251/