On April 30, 2026, OSHA signed CPL 02-02-079, Inspection Procedures for the Hazard Communication Standard (HCS 2024), effective May 19, 2026. It replaces the directive that had been in place since July 2015.
This is not a new regulation. The Hazard Communication standard, 29 CFR 1910.1200, was revised in 2024 to align with the United Nations Globally Harmonized System (GHS). What the directive does is tell every Compliance Safety and Health Officer (CSHO) in the country exactly how to inspect for, document, and cite HazCom violations under the revised rule. It is the inspector’s playbook, and reading it shows a dealer precisely where citations get built and what an inspector reaches for first.
As a franchised dealership, your obligations run to four things:
- Your written program,
- Your workplace labels,
- Your safety data sheets, and
- Your training.
Those same four items are the spine of nearly every HazCom citation, so they are worth understanding through the inspector’s lens.
How Inspectors Build a HazCom Citation
The directive gives CSHOs specific guidance on what to cite when, and the patterns tell you where the exposure is greatest.
If a dealership has done essentially nothing to comply, inspectors are told to issue separate citations, with separate penalties, normally for the written program (e)(1), workplace labeling (f)(6), safety data sheet access (g)(1), and training (h)(2) and (h)(3). Those four items map directly to the four things a dealer actually has to manage.
There is one helpful nuance. If your labels, SDSs, chemical inventory, and training are all in place, but you simply never reduced the program to writing, the directive tells inspectors to treat the missing written program as a de minimis matter rather than a citable violation. That is not a license to skip it, but it shows where OSHA places the weight: on the substance of your compliance, not the paperwork formality.
For ComplyAuto Safety customers, most of this is already handled. The written program, SDS access, and training that anchor a HazCom case are core to the platform, and when the standard moves, as it did with HCS 2024, those updates flow through centrally. The platform’s program and training content reflect the new GHS pictograms and revised SDS format, so customers are not tracking the changes on their own.
Workplace Labeling is Your Highest Day-to-Day Risk
For a dealership, the most common HazCom exposure is the workplace label, also called the secondary or in-house label: the spray bottle of solvent in the service bay, the decanted jug of parts cleaner, the bulk-dispensed container in the lube area. Paragraph (f)(6) requires these to carry, at a minimum, the product identifier plus information on the hazards of the chemical. Three points from the directive trip up shops:
- The “immediate use” exemption is narrow. A portable container is exempt only when the chemical was transferred from a properly labeled container and is intended only for the immediate use of the employee who performed the transfer. A spray bottle one tech fills and leaves for the next shift does not qualify.
- In-house pictograms can use a black border. That is acceptable only for workplace labels, never for anything you ship.
The consumer product exemption is not the shield dealers think it is
Many dealers assume that because a product is sold off the shelf to consumers, it falls outside HazCom. The directive reinforces that this is only sometimes true. A consumer product can lose the exemption when it is used in a way the manufacturer did not intend, or when the frequency and duration of workplace use produces exposures significantly greater than a normal consumer would experience. A technician going through cans of brake cleaner all day is not using the product the way a weekend driver does. Inspectors must document that heavier use before citing, but the practical lesson runs opposite to what most dealers assume: do not lean on the exemption to skip labeling, SDSs, and training for products your shop burns through in volume.
Your Written Program, SDS Library, and Training
Three foundational items round out what an inspector examines, and for ComplyAuto Safety customers, they are managed inside the platform rather than left to you to assemble.
Your written hazard communication program can be generated and kept current in ComplyAuto, including the elements an inspector checks for: a chemical inventory covering every hazardous chemical known to be present, even those in storage and not in use, with identifiers that tie to the SDS.
Your SDS library lives in ComplyAuto with on-demand digital access, which clears the access requirement that trips up shops with a locked cabinet or a password wall a technician cannot get through.
Your training is delivered and tracked through the platform, in a format and at a literacy level your employees can follow.
What To Do Now
A focused dealership review should cover:
- Refresh the chemical inventory.
- Walk every department and audit secondary labels.
- Verify the SDS library is current and genuinely accessible.
- Retrain on the new labels, pictograms, and SDS format.
- Update the written program to reflect the new elements and your current operations.
ComplyAuto helps franchised dealerships manage EHS compliance, including hazard communication, across every department. If you would like a structured HazCom readiness review, schedule a demo, and our team can help.