First employer deadline: November 20, 2026
HazCom 2024 update: a 7-step checklist for dental offices
By Ryan Smith, DDS · Updated October 15, 2026
OSHA updated the Hazard Communication standard (29 CFR 1910.1200) in 2024 to line up with the latest version of the Globally Harmonized System. Most of the changes fall on chemical manufacturers. Employers, including every dental office, update their labels, written program and training as needed for newly identified hazards.
The employer deadlines
The dates come from OSHA's 2026 extension of the original compliance dates. Starting early means your training and records already reflect the 2024 changes when the first deadline arrives.
The checklist
- 1
Name the person who owns Hazard Communication
Pick one person (often the office manager or the infection control lead) to run the update and keep the records. Write their name on the program.
- 2
Walk every room and update the chemical inventory
Operatories, sterilization, lab, x-ray, front office and the janitorial closet. List every hazardous product by the name on its label: disinfectants, sterilants, etchants, bonding agents, amalgam, impression materials, x-ray chemicals, cleaners.
Tip: Add anything new since the last review and remove what you no longer use.
- 3
Get a current Safety Data Sheet for every product
Every product on the inventory needs an SDS your team can reach during every shift, on paper or on a device everyone can use. Replace older sheets as suppliers send updated ones, which now follow the 2024 format.
- 4
Check every secondary container label
Spray bottles of surface disinfectant, ultrasonic and instrument solutions, and anything poured out of its original container need a workplace label with the product name and its hazards. This is where dental offices most often miss.
Tip: Original manufacturer labels must stay on and readable.
- 5
Update the written Hazard Communication program
It lists the chemical inventory, how containers are labeled, where SDSs are kept, how employees are trained, how non-routine tasks are handled, and how you inform contractors who work in the office. Date it and keep the old version.
- 6
Train everyone on the 2024 changes
Start before the first deadline. Cover your program, how to read the updated labels and pictograms, the sections of an SDS and where to find them, the hazards of the chemicals in your office, and how to protect yourself (PPE, ventilation, spill steps). Train new staff at hire and everyone again when a new hazard comes in.
- 7
Write it down
Keep a record of who was trained, on what, on which date and by whom, and sign and date the program review. If you are ever inspected, the record is what you show.
General information, not legal advice. Sources: OSHA Hazard Communication standard, 29 CFR 1910.1200, its 2024 update, and the 2026 compliance-date extension. Your state may add requirements.