The New OSHA Hazard Communication Standard: Care Industry SDS and GHS Compliance Requirements

Under OSHA’s updated Hazard Communication Standard (HCS / 29 C.F.R. 1910.1200), November 20, 2026 is the official employer compliance deadline to update workplace alternative chemical labels, written hazard communication programs, and employee training for chemical substances. 

Care Industries such as funeral homes, veterinary hospitals, cemeteries, and dental offices all must contend with this new regulatory change.

How Do You Know That Every SDS (and GHS Label) Your Company Maintains, Distributes, and Makes Available Is the Right Version—and How Do You Prove It?

That is where electronic SDS management and GHS labels become increasingly important.

What Is Changing Under the Updated Hazard Communication Standard for Care Industries?

The rule includes changes affecting:

• Hazard classification criteria

• Precautionary statements

• Labels and labeling of small containers

• Safety Data Sheet requirements

• Trade-secret provisions

• Chemical hazard information

• Product information supplied downstream

• Certain physical and health hazard classifications

• Alignment with GHS Rev. 7 and international requirements

OSHA specifically notes that affected chemical manufacturers and Care Industries will need to revise SDSs and labels for certain hazardous chemicals to reflect revised classifications and required language.

The important point for Care Industries is that the SDS is not a static document. It is a controlled representation of the company's current understanding of a chemical's hazards. When the underlying hazard information changes, the SDS and GHS label may need to change.

The Three-Month SDS Update Requirement Matters for Care Industries and Manufacturers 

Under OSHA's Hazard Communication Standard, when the manufacturer or importer preparing an SDS becomes newly aware of significant information concerning the hazards of a chemical (or ways to protect against those hazards) that information must be added to the SDS within three months.

Labels have their own update requirements. When a manufacturer, importer, distributor, or employer becomes newly aware of significant information regarding a chemical's hazards, labels must be revised within six months, subject to the standard's requirements.

That creates an important operational question: How is your organization identifying, tracking, approving, publishing, and distributing SDS changes?

If the answer is: "We keep the PDFs on a shared drive." you may have a document repository—but you do not necessarily have a dynamic SDS and GHS label management system.

Electronic SDS and GHS Management Changes the Equation for Care Industries

OSHA permits electronic access to SDS provided that electronic access does not create barriers to immediate employee access. The standard specifically recognizes electronic access as an acceptable alternative to maintaining paper copies when the required conditions are satisfied.

Instead of treating SDSs as documents buried in folders, manufacturers can create a centralized electronic SDS environment where products, chemicals, SDS documents, revisions, labels, and access points are connected.

This is the approach we at Certified Safety Training (CST) has taken with SDS Pro: an A.I. powered electronic SDS and GHS compliance platform.

From an SDS library to an SDS Management System In Care Industries

At Certified Safety Training, SDS management is designed around a simple concept: Employees should be able to find the information they need without having to know where the PDF is stored.

CST provides electronic access to SDS and GHS resources while integrating them into a broader safety and compliance environment. CST's platform includes SDS and GHS labeling resources, compliance management, training, audits, and other safety services.

For organizations with large chemical inventories, this approach can provide several advantages.

1. Centralized SDS access:  Rather than maintaining separate SDS binders at every facility, an organization can establish a centralized source for chemical safety information. Employees can access the information they need electronically while management maintains greater visibility into the organization's SDS inventory.

2. Searchable chemical information: A good SDS system should make it easy to locate a document using information employees actually know. That might include:

• Product name

• Manufacturer

• Chemical name

• Product number

• CAS number

• Location

• Category

• Other identifying information

The goal is to make the SDS available in seconds—not minutes.

3. Version control:  SDS management becomes significantly more useful when organizations can distinguish between current and historical documents. Version control can help answer a fundamental compliance question: Which SDS was current at a particular point in time?

That can be important when investigating an incident, responding to an audit, reviewing a customer inquiry, or determining whether a product's hazard communication has changed.

4. QR-code access:  Electronic SDS management can also extend into the physical workplace. QR codes can provide a direct pathway from a chemical container, cabinet, workstation, vehicle, or facility location to the applicable safety information. Instead of asking an employee to search through a binder or shared drive, the employee can scan the code and access the relevant information.

5. Multi-location management:  For manufacturers operating multiple facilities, centralized electronic management can help reduce the problem of each location maintaining its own version of the SDS library. A corporate compliance team can establish a consistent system while still allowing information to be organized by facility, department, product, or chemical inventory.

6. Connecting SDS management to the broader safety program:  SDS compliance should not exist in isolation. The information contained in SDSs can influence:

• PPE requirements

• Chemical storage

• Spill response

• Emergency procedures

• Employee training

• Hazard communication programs

• Workplace labeling and signage

• Respiratory protection

• Exposure-control measures

In the end, only one question matters for SDS and GHS compliance:  "Can we reliably manage the right SDS and GHS labels, for the right product, at the right location, and make it immediately accessible to the people who need it?"

If the answer is uncertain, now is the time to modernize your SDS management process. 

Turn HazCom Uncertainty into Total Compliance with SDS Pro