Last updated 2026-07-09

TL;DR
Hazard communication (HazCom) is OSHA's standard at 29 CFR 1910.1200. It requires employers to identify chemical hazards, label containers, keep Safety Data Sheets, and train workers to read and act on that information. Any business that uses, handles, stores, or produces hazardous chemicals must comply. There is no size exemption. Serious violations carry penalties up to $16,131 each.
What does hazard communication actually mean?
Hazard communication is the system for telling workers which chemicals around them are dangerous and what to do about it. That's the whole idea. It sounds obvious now. Before OSHA wrote it down, a warehouse worker could spend thirty years handling solvents and never learn they damaged his liver.
The governing rule is 29 CFR 1910.1200, called the HazCom Standard or just HazCom [1]. It covers general industry. Construction gets the same requirements under 29 CFR 1926.59, which adopts the general industry rule by reference, so the substance is identical.
OSHA aligned the standard with the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) in 2012, and the phased compliance deadline ran through June 1, 2016 [2]. That alignment matters for a practical reason: an SDS from a German manufacturer now follows the same 16-section format as one from a company in Ohio.
The standard covers any chemical with a physical hazard (flammable, explosive, reactive) or a health hazard (toxic, carcinogenic, corrosive). OSHA estimates roughly 43 million workers handle hazardous chemicals on the job [1]. Every year, HazCom lands near the top of OSHA's most-cited list. It is not an obscure rule.
What are the 5 required elements of a hazard communication program?
The HazCom Standard has five concrete pieces: a written program, a chemical inventory, container labels, Safety Data Sheets, and employee training. Miss any one and you have a compliance gap, not a paperwork gap. Here is what each piece asks of you.
1. Written hazard communication program. You need a written plan describing how your workplace handles the other four elements. It doesn't have to be long. It has to name who maintains the chemical inventory, where SDSs live, and how you train new hires. The standard says employers must "develop, implement, and maintain at each workplace" a written program [1].
2. Chemical inventory. A list of every hazardous chemical on-site. Everything else builds on this. If you don't know what you have, you can't label it, find its SDS, or train anyone on it.
3. Labels on containers. Every container of a hazardous chemical needs a GHS-compliant label: product identifier, signal word (Danger or Warning), hazard statements, precautionary statements, pictograms, and the supplier's contact information [2]. Pour a chemical into a smaller container at work and that container needs a label too. The one narrow exception is a portable container that a single employee fills and empties within the same shift.
4. Safety Data Sheets (SDSs). Formerly called Material Safety Data Sheets (MSDSs). These follow the 16-section GHS format. You need one for every hazardous chemical in your inventory, and workers must reach them anytime during their shift. Locked in a supervisor's office does not count [1].
5. Employee training. Workers get trained before their first assignment with hazardous chemicals, and again when a new chemical hazard shows up. Training covers how to read labels and SDSs, what the hazards are, and what protects against them. This is not a "read this pamphlet" situation. OSHA wants workers who actually understand.
The written program is the map. The other four are the ground it describes.
How does the GHS system define chemical hazards?
GHS sorts every chemical into two buckets: physical hazards and health hazards. Each bucket holds specific hazard classes, and each class carries numbered categories that rank severity, with Category 1 usually the worst.
Physical hazard classes include flammable liquids, explosives, oxidizers, compressed gases, and self-reactive substances. Health hazard classes include acute toxicity, skin corrosion and irritation, serious eye damage, respiratory sensitization, carcinogenicity, reproductive toxicity, and specific target organ toxicity [2].
Every hazard class and category maps to a set pictogram, signal word, and standardized hazard statement. A flammable liquid Category 1 gets the flame pictogram and the signal word "Danger." A flammable liquid Category 4, much less severe, gets "Warning" and needs no pictogram on the label. Same class, different category, different label.
That tiered structure is what makes a GHS label readable once you learn the vocabulary. Nine pictograms cover the field. The skull and crossbones means acute toxicity. The health hazard pictogram (a human figure with a starburst chest) flags carcinogens and reproductive hazards. The exclamation mark covers irritants and milder systemic effects.
OSHA's HazCom standard is built on GHS Revision 3 as its baseline, and the agency has moved to align with later revisions. Which revision applies matters if you write your own SDSs or evaluate imported chemicals from suppliers working off newer GHS editions [10].
What must a Safety Data Sheet include?
Under 29 CFR 1910.1200 Appendix D, an SDS must carry exactly 16 sections, in order [1]. Mandatory, not suggested. Here they are:
| Section | Title |
|---|---|
| 1 | Identification |
| 2 | Hazard(s) identification |
| 3 | Composition/information on ingredients |
| 4 | First-aid measures |
| 5 | Fire-fighting measures |
| 6 | Accidental release measures |
| 7 | Handling and storage |
| 8 | Exposure controls/personal protection |
| 9 | Physical and chemical properties |
| 10 | Stability and reactivity |
| 11 | Toxicological information |
| 12 | Ecological information |
| 13 | Disposal considerations |
| 14 | Transport information |
| 15 | Regulatory information |
| 16 | Other information |
Section 8 holds the Permissible Exposure Limit (PEL) and Threshold Limit Value (TLV), which tell you whether you need engineering controls or respirators. Section 2 is where emergency responders look first. Section 11 spells out the long-term health consequences of exposure.
OSHA does not require SDSs for consumer products used the same way and at the same frequency a consumer would use them at home. That is the consumer product exemption, and it is narrower than people think. Burn through a case of aerosol cleaner a week in a commercial kitchen and that is not consumer use.
For a walkthrough of one product's SDS, see our guide on the hcl safety data sheet, which breaks down hydrochloric acid across all 16 sections.
Who has to comply with hazard communication requirements?
Any OSHA-covered employer with hazardous chemicals in the workplace. That net is wide. It catches manufacturing plants, auto shops, restaurants (cleaning chemicals count), janitorial companies, construction contractors, salons, and healthcare facilities. OSHA estimates the standard covers roughly 5 million workplaces [1].
There is no size threshold. A three-person cleaning company carries the same labeling and SDS duties as a Fortune 500 chemical maker. The manufacturer has extra work: it must classify its chemicals and prepare the SDS. Downstream employers who only use chemicals lean on the SDS the manufacturer or importer supplies.
State plan states, the 22 states and territories running their own OSHA-approved programs, must adopt standards "at least as effective" as federal OSHA [3]. Most copy the federal HazCom Standard almost word for word. California's Cal/OSHA is the exception worth knowing. Its Hazard Communication Standard (Title 8 CCR 5194) adds requirements, including stricter labeling for certain carcinogens.
If your workers fall under a collective bargaining agreement, that contract may set hazard communication procedures beyond OSHA's floor. Read it.
What does hazard communication training actually have to cover?
29 CFR 1910.1200(h) lays out exactly what training addresses [1]. It is not a general chemical safety lecture. It has to cover:
- The HazCom Standard's requirements and where employees can find the standard and the written program
- Operations in the work area where hazardous chemicals are present
- Where the chemical inventory and SDSs are, and how to get to them
- Methods to detect the presence or release of a hazardous chemical
- The physical, health, and environmental hazards in the work area
- How to protect against those hazards (PPE, work practices, controls)
- How to read and understand labels and SDSs
OSHA sets no mandatory format, length, or test. Enforcement turns on whether workers actually understand, not on which video you played. Inspectors will ask workers directly. If someone who handles a corrosive cleaner can't say what the signal word on the label means or where the SDS is, that's a training failure no matter how thick your binder is.
Training happens before the first assignment, not sometime during onboarding week. Bring a new chemical into the building and the workers handling it need training on that hazard before they touch it.
For how to structure worker safety education more broadly, see our osha training overview, which covers documentation and the split between awareness-level and task-specific training.
One honest caveat: OSHA has no universal "HazCom training record" form. Sign-in sheets, LMS records, or a plain log all work. What matters is proving who was trained, on what, and when.
What are the OSHA penalties for hazard communication violations?
HazCom citations fall into categories with different penalty ranges, and OSHA raises its maximum amounts every year for inflation under the Federal Civil Penalties Inflation Adjustment Act [4]. As of 2024, a serious or other-than-serious violation tops out at $16,131. A willful or repeated one reaches $161,323.
| Violation type | Maximum per violation |
|---|---|
| Other-than-serious | $16,131 |
| Serious | $16,131 |
| Willful or repeated | $161,323 |
HazCom violations usually get cited as "serious" because failing to communicate a chemical hazard can directly cause injury or illness. A missing SDS for a toxic solvent or an unlabeled jug of corrosive cleaner is not a technicality.
HazCom (1910.1200) has ranked in OSHA's top five most-cited standards for over a decade, usually at number two or three [5]. OSHA issued 2,511 HazCom citations in fiscal year 2023 [5]. That is not a niche problem.
Reductions exist. Employers with 25 or fewer workers can get up to 60% off. Those with 26 to 250 workers can get up to 40%. Showing good faith (a written program that exists but has a gap) can cut it further. But the starting point is still the maximum, and every reduction sits at OSHA's discretion after the citation issues.
Repeat violations bite hardest. Cited for missing SDSs in 2021, cited again in 2025, and OSHA can stack the penalty far above the standard maximum. Fix the first citation for real.
What is the difference between HazCom and the old MSDS system?
Before 2012, the HazCom Standard used a non-standardized document called a Material Safety Data Sheet (MSDS). Manufacturers put the information in any order and format they liked. A flammability data point might sit on page 1 of one MSDS and page 7 of another. Emergency responders hated it.
The 2012 update aligned the standard with GHS. It replaced MSDSs with SDSs in a mandatory 16-section format, standardized label elements (pictograms, signal words, hazard statements), and set one consistent hazard classification system [2]. The compliance deadline for most employers was June 1, 2016.
So if you still keep old MSDSs in a binder from 2010, they do not meet the current standard. You need SDSs from your current suppliers in the 16-section GHS format. Most major manufacturers updated by 2016. Smaller or international suppliers sometimes lagged, so spot-check.
The underlying idea never changed: tell workers what's dangerous and how to protect themselves. The 2012 update just made the language consistent enough that a worker trained in New York can pick up an SDS from a Japanese manufacturer and read it.
How does hazard communication connect to other OSHA standards?
HazCom doesn't stand alone. It feeds several other OSHA standards, and when those apply, the requirements stack on top of each other.
Personal protective equipment (PPE) under 29 CFR 1910.132 requires a hazard assessment before you pick PPE [6]. SDS section 8 (exposure controls and personal protection) is one of the main inputs to that assessment. Skip the SDS and you probably picked the wrong glove.
Process Safety Management (PSM) under 29 CFR 1910.119 covers facilities handling highly hazardous chemicals above threshold quantities [7]. PSM builds on HazCom and adds process hazard analysis, operating procedures, and mechanical integrity for listed chemicals.
Respiratory protection under 29 CFR 1910.134 kicks in when engineering controls can't hold airborne concentrations below the PEL listed in the SDS [8]. No SDS means no known PEL, which means no way to judge whether a respirator is needed.
Lockout tagout under 29 CFR 1910.147 intersects with HazCom when workers service equipment that holds or moves hazardous chemicals. Energy isolation procedures have to account for the chemical hazard, not only the electrical or mechanical one.
An incident report after a chemical exposure almost always sends you back to the SDS to learn what was released and what it does to the body. If that SDS was wrong, missing, or outdated, the problem compounds.
Treating HazCom as a standalone paperwork exercise misses what it does. It is the information backbone the other standards run on.
How do you write a hazard communication program from scratch?
Start with the chemical inventory. Walk every area of the facility and list every product with a hazard label: cleaning chemicals, lubricants, paints, adhesives, fuels, pesticides, compressed gases. Don't skip the products workers bring in themselves, like the personal hand sanitizer that quietly becomes a workplace chemical.
For each item, confirm you hold an SDS in the 16-section GHS format. If a supplier never sent one, request it. They are legally required to provide it. Can't get one? Don't use the chemical.
Then write the program document. It needs to: 1. Name who maintains the chemical inventory and SDSs 2. Describe how containers get labeled, including secondary containers 3. Explain where SDSs are stored and how workers reach them 4. Describe when and how workers are trained 5. Address non-routine tasks (spill cleanup, maintenance on chemical systems) 6. Address contractors who bring their own chemicals on-site (you need their SDS, they need yours)
The contractor piece trips up small employers. If a painting contractor brings his own solvents, OSHA requires you to make that information available to your employees who might be exposed [1]. You don't write his SDS. You do make sure your workers can get to it.
If building the program from scratch feels like a lot, SafetyFolio's safety program generator walks you through the required HazCom elements in about 15 minutes and outputs a document you can actually use, not a blank template to fill in.
Review the written program at least once a year and any time a significant new chemical hazard enters the workplace. A program that was accurate in 2019 can develop gaps the moment your cleaning supplier changes a formulation.
What are common HazCom mistakes that lead to OSHA citations?
Missing or outdated SDSs are the most common citation. Second is unlabeled secondary containers: someone pours bleach into a bare spray bottle and parks it on the cleaning cart. Both are easy to fix and easy for an inspector to spot.
The other frequent gaps:
No written program. Plenty of small employers train workers verbally and keep SDSs in a binder but never produce the written plan describing the system. OSHA treats the written program as its own citable element.
SDS access issues. SDSs locked in a manager's office, sitting on a computer workers can't open, or written in a language workers can't read. The standard says SDSs must be "readily accessible to employees in their work area(s) during each work shift" [1].
Training not documented. You trained workers last year, but there's no record of who came, what you covered, or when. OSHA doesn't demand a specific training record the way it does for a respirator fit test, but inspectors will ask employees to describe their training, and if nobody can, the citation follows.
Chemical inventory not updated. The shop bought a new product six months ago. Nobody added it to the inventory, nobody pulled an SDS, and workers are using it blind.
Relying on old MSDSs. Binders of pre-2016 Material Safety Data Sheets in the non-standardized format don't satisfy the current standard.
The pattern is clear. HazCom citations cluster in industries where chemical use is so routine it turns invisible: janitorial, restaurant, auto repair, light manufacturing. The chemicals aren't exotic. The attention is what's missing.
Does hazard communication apply to small businesses?
Yes. There is no size exemption in 29 CFR 1910.1200. A sole proprietor with one employee using industrial cleaning chemicals carries the same labeling and SDS duties as a 500-person chemical plant. The penalty reduction schedule (up to 60% off for employers with 25 or fewer workers) softens the financial hit if you get cited. It does not erase the requirement.
OSHA does exempt some employers from its jurisdiction entirely: farms with ten or fewer employees and no temporary labor camps, for example, and domestic service workers. But those limits come from OSHA's general authority, not from HazCom itself.
Small business owners often figure that common commercial products (dish soap, drain cleaner, spray lubricant) put them outside HazCom. They don't. The consumer product exemption only covers products used the same way and as often as a household would. A restaurant burning through a gallon of degreaser per shift is not household use.
The real difference for small employers is length. A two-person painting contractor's HazCom program looks nothing like a petrochemical plant's, and it shouldn't. OSHA's own Small Business Safety and Health Handbook treats the standard as scalable to the actual hazards on-site [9].
For the wider framework you're operating in, see our osha overview, which covers which employers fall under federal versus state-plan jurisdiction.
Frequently asked questions
What is the OSHA standard number for hazard communication?
The primary standard is 29 CFR 1910.1200, covering general industry. Construction workers fall under 29 CFR 1926.59, which adopts the general industry rule by reference. Maritime industries adopt it under 29 CFR 1915.99, 1917.28, and 1918.90. All of them point to the same GHS-aligned requirements that have been in effect since 2016.
What is the difference between an SDS and an MSDS?
An MSDS (Material Safety Data Sheet) was the pre-2016 format, with no standardized section order or content. An SDS (Safety Data Sheet) follows the GHS 16-section format OSHA adopted in 2012. Old MSDSs do not meet the current standard. If your binders still say MSDS, request updated documents from your chemical suppliers.
How often does hazard communication training need to be repeated?
OSHA's HazCom Standard requires training before initial assignment and whenever a new chemical hazard shows up. There is no mandatory annual retraining in the standard itself. But bring in a new solvent, a new pesticide, or a different cleaning product and the workers handling it need training before they start using it. Some state-plan states add refresher requirements of their own.
What are the 9 GHS pictograms and what do they mean?
The nine are: flame (flammables, pyrophorics), flame over circle (oxidizers), exploding bomb (explosives, self-reactives), skull and crossbones (acute toxicity), corrosion (skin/eye corrosion, metal corrosion), gas cylinder (compressed gases), health hazard (carcinogens, reproductive toxins, respiratory sensitizers), exclamation mark (irritants, milder hazards), and environment (aquatic toxicity). The environment pictogram is not required under OSHA's standard but may appear on labels.
Does a small business with only cleaning chemicals need a written HazCom program?
Yes. 29 CFR 1910.1200 requires every covered employer to keep a written hazard communication program, no matter how common or low-hazard the chemicals look. The written program just describes your chemical inventory, labeling process, SDS location, and training approach. For a business with a handful of cleaning products, one or two pages does it.
What is a signal word on a chemical label?
A signal word is one of two terms, Danger or Warning, that appears prominently on a GHS label to show relative hazard severity. Danger flags the more severe categories within a class; Warning flags the less severe ones. A container carries only one signal word. If multiple hazards are present with different signal words, Danger wins.
Are employers required to provide SDSs in the language workers speak?
OSHA's HazCom Standard requires that employees understand the hazard information. An SDS in a language workers can't read doesn't satisfy that. OSHA's enforcement guidance expects employers to give workers information in a form they can comprehend. Translated SDSs or bilingual training is the practical move when you have a multilingual workforce.
What chemicals are exempt from the OSHA HazCom Standard?
Several categories: hazardous waste regulated by EPA under RCRA, tobacco products, wood and wood products (where the hazard is the wood itself, not a coating), food and drugs meant for personal consumption by employees, articles (solid objects that don't release chemicals under normal use), and consumer products used as a consumer would. Each exemption has conditions. When in doubt, treat the chemical as covered.
What happens if a supplier doesn't send me an SDS?
Request one in writing. Under 29 CFR 1910.1200(g)(6), chemical manufacturers and distributors must provide an SDS to downstream employers on request. If you can't get one, OSHA's position is that you shouldn't use the chemical until you can document its hazards. Keep copies of your SDS requests in case OSHA asks why a sheet is missing.
How is hazard communication enforced by OSHA?
OSHA enforces HazCom during programmed inspections (targeting high-hazard industries), unprogrammed inspections from complaints or incidents, and follow-up inspections after prior citations. Inspectors check container labels, ask to see the SDS binder or digital system, review the written program, and interview workers. HazCom sits in the top five most-cited standards every year, so inspectors know exactly what to look for.
Can SDSs be stored electronically instead of in a paper binder?
Yes. OSHA permits electronic SDS access as long as workers reach the documents immediately during their shift with no barriers. The system needs a reliable backup for power or system failures, and workers must be trained to use it. A locked computer in a manager's office that workers need permission to touch does not meet the 'readily accessible' bar.
What is a hazard communication program audit?
A HazCom audit is a systematic review of your program against 29 CFR 1910.1200. It checks that your chemical inventory is current, every chemical has a compliant SDS, all containers are labeled, the written program is up to date, and training records exist for current employees. Running an internal audit once a year, before OSHA does it for you, is the cheapest way to stay ahead of citations.
Sources
- OSHA, 29 CFR 1910.1200 Hazard Communication Standard (full regulatory text): Requirements for written program, SDSs, labels, training, and scope covering approximately 43 million workers and 5 million workplaces
- OSHA, Hazard Communication: Understanding the 2012 revisions (GHS alignment): 2012 alignment with GHS Revision 3, mandatory 16-section SDS format, standardized label elements, and June 2016 compliance deadline
- OSHA, State Plans overview: 22 states and territories run OSHA-approved state plans that must be at least as effective as federal OSHA standards
- OSHA, Penalties (civil penalty amounts and inflation adjustments): Maximum serious and other-than-serious penalty of $16,131 per violation; maximum willful or repeated penalty of $161,323 per violation as of 2024
- OSHA, Top 10 Most Cited Standards FY2023: HazCom (1910.1200) ranked in top five most-cited standards with 2,511 citations in FY2023
- OSHA, 29 CFR 1910.132 Personal Protective Equipment (general requirements): PPE standard requires hazard assessment prior to PPE selection; SDS section 8 is a key input to that assessment
- OSHA, 29 CFR 1910.119 Process Safety Management of Highly Hazardous Chemicals: PSM applies to facilities handling highly hazardous chemicals above threshold quantities and builds on HazCom requirements
- OSHA, 29 CFR 1910.134 Respiratory Protection: Respiratory protection required when engineering controls cannot keep airborne chemical concentrations below the PEL listed in the SDS
- OSHA, Small Business Safety and Health Handbook (OSHA 2209-02R 2005): OSHA acknowledges that HazCom programs are scalable to the actual hazards present in a small workplace
- United Nations Economic Commission for Europe, GHS (Globally Harmonized System) Purple Book: GHS classification system for physical and health hazards, pictogram assignments, and hazard category structure