OSHA Revisions to the Hazard Communication Standard

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OSHA Revisions to the Hazard Communication Standard

Reference Number: MTAS-1892
Reviewed Date: 09/04/2026

Your text is accurate as historical background, but it needs several updates. The 2012 GHS transition was completed in 2016, and OSHA issued further Hazard Communication Standard amendments in 2024 and 2026 to align more closely with GHS Revision 7 and selected elements of Revision 8. A city should follow the current version of 29 C.F.R. § 1910.1200 and applicable TOSHA rules rather than present the 2012 transition schedule as a current compliance program.

Hazard Communication
Tennessee cities must comply with applicable Tennessee Occupational Safety and Health Administration (TOSHA) hazardous-chemical and hazard-communication requirements. Tennessee operates an OSHA-approved state plan, and TOSHA enforces the federal Hazard Communication Standard, 29 C.F.R. § 1910.1200, as adopted or implemented under state law, along with applicable provisions of the Tennessee Hazardous Chemical Right-to-Know Law.

The Hazard Communication Standard is designed to ensure that employees receive understandable information about the hazardous chemicals to which they may be exposed in the workplace. The standard applies to hazardous chemicals known to be present in the workplace in a manner that employees may be exposed under normal working conditions or in foreseeable emergencies.

City Responsibilities
The city must establish and maintain an effective written hazard-communication program. The program must address workplace chemical labeling, safety data sheets, employee information and training, and a current workplace chemical list or inventory.

Each city department that uses, stores, handles, or may expose employees to hazardous chemicals should:

  • Maintain a current inventory of hazardous chemicals in the work area.
  • Ensure that shipped chemical containers are properly labeled and that workplace containers are labeled or otherwise identified as required.
  • Maintain an accessible Safety Data Sheet (SDS) for each hazardous chemical.
  • Make SDSs readily available to employees during each work shift.
  • Provide employees with information and training before their initial assignment to work involving hazardous chemicals and whenever a new chemical hazard is introduced into their work area.
  • Provide additional training as necessary to ensure employees understand chemical hazards, protective measures, safe-handling procedures, container labels, pictograms, signal words, hazard statements, precautionary statements, and SDS information.

The city must train all employees who may be exposed to hazardous chemicals, including full-time, part-time, temporary, seasonal, and volunteer personnel when their duties create potential exposure. Training must be provided in a manner and language employees can understand. The city should use methods appropriate to employees with limited literacy, limited English proficiency, or learning needs, such as instructor-led explanations, demonstrations, visual aids, and opportunities for questions and confirmation of understanding.

Labels and Safety Data Sheets
Chemical manufacturers, importers, and distributors are generally responsible for classifying hazards and providing compliant shipped-container labels and SDSs. City departments must ensure that hazardous-chemical containers in the workplace remain properly labeled and that employees can access the corresponding SDSs.

Hazard labels generally include:

  • A product identifier.
  • Supplier identification.
  • A signal word, such as “Danger” or “Warning.”
  • Hazard statement(s).
  • Precautionary statement(s).
  • Applicable pictogram(s).

An SDS uses a standardized 16-section format and provides information about a chemical’s hazards, ingredients, safe handling and storage, exposure controls, personal protective equipment, first-aid measures, emergency response, and disposal considerations.

Retention and Training
The city must maintain an SDS for each hazardous chemical while the chemical is used or stored in the workplace. The city should preserve historical SDSs or maintain a record of the chemical’s identity, the period it was used, and its location of use when necessary to meet employee-exposure record requirements. Exposure records generally must be retained for at least 30 years.

Tennessee’s Right-to-Know rules also require employers to maintain and update a workplace chemical list and provide employee information and training at initial assignment, when a new hazard is introduced, and at least annually thereafter.

The city should document hazard-communication training, including the training date, instructor, affected department or work area, topics covered, and employees who attended. While federal HazCom rules focus on providing effective training rather than prescribing a specific training-record format, documentation helps demonstrate compliance and identify when refresher training is needed.

2024–2026 Updates
The 2012 HCS revisions first aligned OSHA’s standard with the United Nations GHS and established the familiar SDS format and standardized label elements. Those initial transition deadlines ended in 2016.

OSHA subsequently revised the Hazard Communication Standard in 2024, with implementation deadlines that vary by obligation and chemical type. Cities should review supplier labels and SDSs, update their written hazard-communication program, and provide affected employees updated training as revised labels, SDSs, or newly classified hazards become applicable. Industry guidance identifies a November 20, 2026 deadline for workplace labels, written programs, and training for substances, with a later May 19, 2028 deadline for mixtures.


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