Direct answer: Build a current implementation calendar from primary sources.
Substance SDS and label milestone
OSHA’s current extension page identifies May 19, 2026 for manufacturers of substances to comply with updated SDS and label provisions.
Employer substance milestone
The current OSHA schedule identifies November 20, 2026 for related workplace updates for newly identified physical, health or other hazards for substances.
Mixture SDS and label milestone
The extended date shown for manufacturers of mixtures is November 19, 2027.
Employer mixture milestone
The current schedule identifies May 19, 2028 for the related employer updates for mixtures.
Manage dates as sourced data
Store each milestone with source URL, retrieval date and review status. Recheck OSHA notices before operational decisions because correction notices or later actions can alter implementation details.
Practical example
A portfolio dashboard tags every item as substance or mixture, records the current SDS basis, assigns the applicable milestone, and links directly to OSHA’s current extension notice for the reviewer.
Release checklist
- Verify dates on OSHA’s current page
- Separate substances and mixtures
- Track manufacturer and employer milestones
- Record transition basis per version
- Recheck official notices before release
Common mistakes
- Using pre-extension dates
- Applying the mixture deadline to substances
- Treating a blog summary as the regulatory source
Frequently asked questions
Why do some older pages show different dates?
The final rule schedule was later extended. Use OSHA’s current extension and rulemaking pages.
Can an organization comply earlier?
A transition plan may move earlier, but the selected standard and output should remain consistent and documented.
What can be used during the transition?
OSHA describes compliance with the prior standard, the updated standard, or both during the transition; verify the official wording for the product and date.
Should the software alert on these dates?
Yes, but alerts should be based on reviewed regulatory records, not permanent hard-coded prose.
Primary sources
Review notice: EXPERT US REGULATORY REVIEW REQUIRED BEFORE INDEXING OR COMMERCIAL RELIANCE.