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Less Than 1 Month to November 20. Is Your HazCom Training Complete?

Labels, written program, training. Check all three before the deadline checks you.

Download the free HazCom GHS Compliance Checklist
Three colleagues reviewing overdue safety training records on a laptop in a warehouse office.

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One Checklist. Three Prongs. No Guesswork.

For employers working with pure hazardous substances, OSHA’s revised Hazard Communication Standard has three requirements due November 20, 2026: updated workplace labels, a revised written HazCom program, and employee training that reflects the updated GHS classifications. This checklist walks you through all three, starting with a quick self-ID table that tells you whether November 20 applies to you at all.

  • Prong 1 Updated workplace labels
  • Prong 2 A revised written HazCom program
  • Prong 3 Employee training on the updated GHS classifications

Free checklist

Get Your Free HazCom GHS Compliance Checklist

  • A substances vs. mixtures self-ID table, so you know which deadline is yours
  • A labeling audit with a fill-in log for every work area
  • A written program review covering your inventory, SDS library, and training section
  • A training status table by employee group, including new hires, role changes, and contractors
  • Course recommendations matched to every gap you find

From the blog

Article preview

A team reviewing a training status board marked overdue.

Why Safety Compliance Training Falls Out of Date: 5 Costly Signs Yours Already Has

Nobody schedules training to go out of date. It happens when a standard gets revised and the course you bought against the previous version quietly stops matching what’s required. The GHS revision to the Hazard Communication Standard is the live example, and for employers working with pure hazardous substances, the November 20 deadline is less than a month away. This article covers five signs your training has already fallen behind, three cross-checks for spotting OSHA and EPA training gaps, and what November 20 actually requires.

Read the full article

FAQ

Frequently asked questions

Why does safety compliance training fall out of date?

Safety compliance training falls out of date when the regulation underneath it changes and the training doesn’t. It doesn’t expire on a calendar. When OSHA revised the Hazard Communication Standard to align with the updated GHS, training built on the prior version became incomplete, even for employees trained recently.

How do I know if my safety compliance training is out of date?

Start by pulling a recent completion record and checking whether it identifies which course version was taken. Other signs include a last content review that predates the GHS revision, supplier SDSs that look different from what employees were trained on, and a written HazCom program that still describes superseded label elements.

What does the November 20 HazCom deadline require?

Employers working with pure hazardous substances must meet three requirements by November 20, 2026: updated workplace container labels, a revised written HazCom program, and employee training that reflects the updated GHS classifications. The three prongs travel together, so completing one or two doesn’t close the gap.

Does the November 20 deadline apply to mixtures?

Not for mixtures. The November 20, 2026 employer deadline applies to pure substances; the employer compliance date for mixtures is May 19, 2028. If your workplace handles both, prioritize your substances now. Check Section 3 of a chemical’s SDS if you’re unsure which category it falls into.

How do I spot OSHA and EPA training gaps?

Compare your assignment lists to current rosters, because employees who were never assigned training won’t show up as incomplete. At HAZWOPER-regulated and SPCC-covered sites, verify the names on your spill response and emergency plans against current completion. Then confirm with your provider which version of the standard each course reflects.