The service manager, purchasing lead and project manager can all be looking at the same job and working from different records. A safety data sheet may be in the shop while the crew is at a jobsite. A distributor’s quote may name the system without documenting when its components were made. A refrigeration customer may know the model number but have no record of the full refrigerant charge. Those gaps matter under three federal rules this winter.

1. November 20: Check what changed in your chemical safety information

Under OSHA’s updated Hazard Communication Standard, November 20, 2026 is the employer deadline to update workplace labels, the written hazard communication program and employee training as necessary for substances. The rule calls for additional training on newly identified hazards. The corresponding employer deadline for mixtures is May 19, 2028. That later date does not suspend existing hazard communication duties.

Start with one truck and one shop shelf. Match what crews actually use to the current safety data sheets, including materials transferred into workplace containers. If a revised sheet identifies a hazard the crew hasn’t been trained on, make sure that change reaches the people handling the material. Give one person responsibility for checking the remaining trucks and closing out any gaps.

Source: OSHA’s Hazard Communication Standard compliance-date extension, 91 FR 1695: www.federalregister.gov/d/2026-00653

2. January 1: Check the paperwork on VRF jobs slipping into 2027

The EPA’s ordinary installation window closes January 1, 2027 for covered new residential or light commercial variable refrigerant flow systems that use a regulated refrigerant or blend with a global warming potential of 700 or more and qualify because all specified components were manufactured or imported before January 1, 2026. A narrower exception runs until January 1, 2028 if the project has an approved building permit issued before October 5, 2023 that specifies the restricted refrigerant or blend for that system, and the same component-date condition is met.

Review open jobs before promising an installation date. Ask the supplier for documentation covering all specified components and pull the approved permit if the job depends on the later exception. A purchase order or a delivery date alone does not establish that the components meet the rule. If the job no longer fits the window, discuss an alternate equipment selection before the crew mobilizes.

Source: 40 CFR 84.54(c)(2): www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-84/subpart-B/section-84.5

3. January 1: Identify older refrigeration systems that need automatic leak detection

Owners and operators of covered commercial refrigeration and industrial process refrigeration equipment installed from January 1, 2017 through December 31, 2025 must install and use automatic leak detection by January 1, 2027. The rule applies at a full charge of 1,500 pounds or more where the refrigerant contains an HFC or an HFC substitute with a global warming potential greater than 53. A system used solely for comfort cooling is outside this provision.

Contractors can help customers sort the equipment list by use, installation date, refrigerant and full charge. If the equipment is covered, confirm who will install or verify the detection system, who receives the alert and who will handle the annual audit and calibration. Put those names in the service file so the first alert doesn’t start a search for the person responsible.

Source: 40 CFR 84.108: www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-84/subpart-C/section-84.108

The useful question for the next operations meeting: Which job or asset are we assuming is covered or exempt, and what record would prove it? Start with that one.

Note: Shop On Fire Legal Intelligence provides source-traceable business commentary and research; it is not a law firm. This article is general education, not legal advice. Contractors should consult qualified counsel about the law and facts in their jurisdiction.