Are end-user employers allowed to maintain existing stock or shipped containers with old-style hazard communication labels, or do they need to relabel the containers?

End-user employers with existing stock or who have received shipped containers of hazardous chemicals with HCS-1994- or HCS-2012-compliant labels (old-style labels) are allowed to maintain and use those containers with the old-style labels. However, OSHA notes that:

• The end user must not remove or deface any chemical containers with old-style labels, unless the end user immediately marks the containers with workplace in-house labeling.
• If an end user receives new labels from an upstream supplier for its existing stock, it is advisable to affix the new label over the old-style label; although, it is not required.
• The end user is responsible for training its employees regarding any new label elements.
• When maintaining any shipped containers with HCS-1994-compliant labels, the end user must ensure that employees understand the differences between the HCS-1994-compliant labels and modern HCS labels, and that the lack of pictograms, signal words, etc., does not mean the chemical is without hazards.

In addition, be aware that on or after:

• June 1, 2016, employers must update any alternative workplace labeling, as necessary, for changes related to HCS 2012;
• July 20, 2026, employers must update any alternative workplace labeling, as necessary, for changes related to HCS 2024 for substances; and
• January 19, 2028, employers must update any alternative workplace labeling, as necessary, for changes related to HCS 2024 for mixtures.