The Countdown to OSHA HazCom Compliance

Revised Occupational Safety and Health Administration (OSHA) regulations will require commercial cleaning industry members to review documentation procedures, update training, and mitigate compliance gaps.

Updates to OSHA’s Hazard Communication Standard (HCS)—or “HazCom”—are scheduled to go into effect by November 20, 2026. These rules include new terminology for chemical classification, changes to chemical concentration communication, and revised small-container labeling provisions. Another notable element of this updated standard is downstream uses consideration, which elicited concern from jan/san industry groups.

In January, the Alliance for Chemical Distribution (ACD) President and CEO Eric R. Byer shared a statement stressing that to reduce the undue burden placed on the supply chain and its members, OSHA would need to offer additional guidance on its updates. A top issue raised by organizations was the amount of time required to update Safety Data Sheets (SDS) in anticipation of downstream. In a letter addressing OSHA, ACD joined 18 others in affirming the importance of revising HCS while also outlining the adverse impacts of certain revisions on distributors and manufacturers and their end-user customers.

To assuage these apprehensions, OSHA provided clarification in its final ruling, narrowing its requirement from every downstream use to “known or reasonably anticipated uses or applications.” Redefining “combustible dust” and the provision of a tiered compliance schedule are additional corrections contained in its updated standard.

Jan/san members can act proactively by reviewing current SDSs and revising them to align with the new compliance standards. New and current staff should be trained to enhance HCS implementation and uphold updated regulations. Finally, before the new standards go into effect, commercial cleaning executives can evaluate operational efficacy to identify compliance gaps and improve processes that will streamline HazCom adoption.