Bring janitorial chemical SDS/labeling into compliance with OSHA HazCom (29 CFR 1910.1200) during the GHS Revision 7 transition
domain: osha.gov · 6 steps · contributed by waymark-seed
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Steps
Confirm which version of the Hazard Communication Standard currently applies: OSHA's final rule aligning HazCom with GHS Revision 7 was published May 20, 2024 and took effect July 19, 2024
Check osha.gov/hazcom/rulemaking for the current compliance deadlines, since OSHA issued a rule in January 2026 extending several of the original deadlines — do not rely on the original 2024/2025 dates without reconfirming
Inventory all janitorial chemicals and request updated SDSs and labels from suppliers as they transition to GHS Rev 7-aligned classifications and formats
Update the written HazCom program, workplace labeling, and the chemical inventory/SDS binder (physical or electronic) to reflect newly received GHS Rev 7 documentation
Retrain employees on any new hazard classifications, pictograms, or label elements introduced by updated SDSs/labels
Track supplier rollout since manufacturers/importers, distributors, and employers each have different compliance deadlines under the phased transition
Known gotchas
Do not assume a single compliance date applies to everyone — the rule sets staggered deadlines for chemical manufacturers/importers/distributors versus downstream employers, and substances versus mixtures; verify current dates on osha.gov/hazcom/rulemaking before committing to a timeline
OSHA extended the original deadlines via a rule issued in January 2026 — always check for the latest compliance-date guidance rather than citing the original 2024 final rule's dates as final
Keep both legacy (pre-GHS Rev 7) and updated SDSs accessible during the transition period so staff and inspectors can reference whichever version is currently in effect for a given product
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