Hazard communication and safety data sheets: the complete SDS guide

Last updated 2026-07-10

What is hazard communication and why does OSHA regulate it?

Hazard communication, HazCom for short, is OSHA's system for making sure workers know what chemicals they handle and what those chemicals can do to them. The governing rule is 29 CFR 1910.1200, which covers general industry. Construction, maritime, and agriculture have parallel rules, but 1910.1200 is the one most small businesses need.

The standard has three moving parts: labels on containers, Safety Data Sheets (SDSs) for each chemical, and worker training. Miss any one and you have a violation. HazCom has landed in OSHA's top 10 cited standards every year for more than a decade. In fiscal year 2023 it ranked number two overall with 2,179 violations cited ^[1].

The logic is simple. A worker who doesn't know a cleaning product releases chlorine gas in a confined space can't protect against it. Labels and SDSs close that knowledge gap. The rule doesn't ask you to eliminate every chemical risk. It asks you to communicate the risk accurately.

OSHA aligned 1910.1200 with the United Nations Globally Harmonized System of Classification and Labelling of Chemicals (GHS) in 2012, with the main compliance deadline in June 2016 ^[6]. That alignment is why SDSs now follow a fixed 16-section format, and why the old MSDS (Material Safety Data Sheet), which had no required structure, is dead.

Who does the hazard communication standard apply to?

If your business makes, imports, uses, or stores hazardous chemicals and has even one employee, 1910.1200 applies. The standard covers general industry under 29 CFR 1910.1200, construction under 29 CFR 1926.59, shipyard employment under 29 CFR 1915.99, and marine terminals under 29 CFR 1917.28 ^[2].

The exemptions are narrow. Hazardous waste regulated under RCRA, tobacco products, wood and wood products in their natural state, foods, drugs, and cosmetics intended for personal use are out. But those carve-outs are genuinely small. A repair shop using brake cleaner, degreasers, and battery acid? Fully covered. A restaurant using industrial cleaning chemicals? Covered for those chemicals.

Chemical manufacturers and importers carry the heaviest load. They classify the hazards of their products and prepare compliant labels and SDSs. Distributors pass those documents down the supply chain. Employers at the end of that chain, the ones whose workers actually touch the stuff, maintain the SDSs, keep them accessible, and train their people. If a supplier can't hand you an SDS for a product you buy from them, fix that before the chemical enters your workplace.

What are the 16 required sections of a Safety Data Sheet?

OSHA's Appendix D to 1910.1200 sets the exact 16-section format. Every SDS must contain all 16 sections in this order ^[12]:

Section	Title	Key content
1	Identification	Product name, manufacturer contact, recommended uses, emergency phone
2	Hazard(s) identification	GHS hazard classification, signal word (Danger/Warning), hazard statements
3	Composition/ingredients	Chemical names, CAS numbers, concentration ranges
4	First-aid measures	What to do immediately if someone is exposed by each route
5	Fire-fighting measures	Suitable extinguishing agents, flash point, special hazards
6	Accidental release measures	Spill cleanup procedures, containment
7	Handling and storage	Safe handling practices, storage conditions, incompatibilities
8	Exposure controls/PPE	OSHA PELs, ACGIH TLVs, required PPE, ventilation needs
9	Physical and chemical properties	Flash point, boiling point, vapor pressure, pH, appearance
10	Stability and reactivity	Conditions to avoid, incompatible materials, decomposition products
11	Toxicological information	Routes of exposure, LD50 values, carcinogenicity listings
12	Ecological information	Environmental fate (not enforced by OSHA but still required)
13	Disposal considerations	Waste disposal methods
14	Transport information	DOT/IATA/IMDG shipping info
15	Regulatory information	TSCA, SARA 311/312, state right-to-know lists
16	Other information	Revision date, SDS preparer info

Sections 12 through 15 belong in the SDS, but OSHA doesn't enforce them directly. Your workers still benefit from the information, and a vendor who drops those sections entirely is handing you a sloppy document.

Section 8 is the one that earns its keep day to day. It tells you what PPE workers need, what ventilation controls the chemical calls for, and what the regulatory exposure limits are. Pull that section first when a worker asks about safe handling. For real-world examples, see our guide to the HCl safety data sheet and our methanol safety data sheet breakdown.

What are the labeling requirements under HazCom?

Every container of a hazardous chemical in your workplace needs a label. OSHA's GHS-aligned system requires six elements on any label a manufacturer or importer prepares ^[2]:

1. Product identifier (name or code that matches the SDS) 2. Signal word (either "Danger" for more severe hazards or "Warning" for less severe) 3. Hazard statements (standardized phrases like "Causes serious eye damage") 4. Precautionary statements (what to do to protect yourself and others) 5. Pictograms (the nine GHS pictograms, each in a red diamond border) 6. Supplier identification (name, address, and phone number of the manufacturer or importer)

Containers you fill yourself, like a spray bottle drawn from a bulk drum, need a label too, just not as formal. At minimum it needs the product identifier plus words, pictures, or symbols that convey the hazard. The rule in 29 CFR 1910.1200(f)(7) lets employers use any system that effectively communicates hazard information for these secondary containers.

Portable containers are where people get burned. A worker fills a small bottle with solvent, plans to use it right away, then gets called off. The bottle sits. Someone else picks it up. Now you have an unlabeled hazard and an easy OSHA citation. The immediate-use exemption is narrow: the container must be used during the same shift by the person who filled it, and it stays in their control ^[2].

How do you maintain and provide access to SDSs?

You must have an SDS for every hazardous chemical you use, current version, one per product, available on every shift. OSHA's rule at 1910.1200(g)(8) requires employers to maintain SDSs in the workplace for each hazardous chemical in use ^[2].

Access is where small businesses cut corners. Workers must be able to reach the SDS for any chemical they handle, at any time during their shift, without asking a supervisor for permission. A binder in a locked office doesn't cut it. A terminal that demands a manager login doesn't cut it.

Three storage setups work in practice: paper binders (still the most reliable when computers die or networks drop), dedicated terminals with no login barrier, or a combination of both. Electronic access is fine as long as you keep a reliable backup for network outages and your workers actually know how to use it ^[2].

Manufacturers, importers, and distributors must send the SDS with or before the first shipment of a product, and again with any shipment after the SDS changes. As the employer, request updated SDSs when the revision date on your copy is more than three to five years old, or when you hear a product's formula changed.

No OSHA rule forces you to keep SDSs for chemicals you've stopped using, but keep them anyway. If a worker develops an occupational illness years later and needs to know what they were exposed to, that old SDS is the evidence. The OSHA medical records rule, 29 CFR 1910.1020, requires exposure records to be kept 30 years, and OSHA's letters of interpretation have treated SDSs for chemicals in use during that window as part of those records ^[7].

What does a written hazard communication program require?

This is the piece small businesses forget. 29 CFR 1910.1200(e) requires a written hazard communication program, more than a stack of SDSs. The program has to describe how your company handles each element of HazCom: labels, SDSs, and training ^[2].

At minimum, your written program must address:

• How you ensure containers are labeled (including who labels secondary containers)
• How workers access SDSs and where they're kept
• How you conduct HazCom training and when
• A list of all hazardous chemicals in the workplace, by work area or for the whole facility
• How you handle non-routine tasks (cleaning a reactor that normally holds a hazardous material, for example)
• How you address hazards from contractors who bring their own chemicals on site

That last one surprises people. When a contractor brings a chemical into your facility, you're on the hook for making sure your workers know about it. You coordinate with the contractor to get the SDSs and share them.

The written program doesn't have to be long. Two to four pages covers most small operations. What it can't be is generic. OSHA compliance officers are trained to spot boilerplate that doesn't match how the business runs. A program that names specific job titles for SDS maintenance and names the actual room where SDSs live beats one that says "a designated employee will ensure."

If you want a compliant written HazCom program fast, SafetyFolio's safety program generator walks you through the required elements and produces a document specific to your workplace, not a template you have to rewrite yourself.

What HazCom training do employees need?

Train workers before they're first exposed to a hazardous chemical, and again whenever a new chemical enters the workplace ^[2]. That timing is non-negotiable. Training after an exposure event is too late.

OSHA's 1910.1200(h) spells out what the training must cover:

• The existence and requirements of the HazCom standard itself
• The location and availability of the written program and SDSs
• The physical and health hazards of chemicals in the work area
• How to detect the presence or release of a hazardous chemical (senses or monitoring equipment)
• Protective measures, including work practices, emergency procedures, and PPE
• How to read labels and SDSs and pull information from them

OSHA sets no minimum training hours and no required format. Classroom, online, hands-on, or a mix, all pass if they actually transfer knowledge. What OSHA does require is that training be understandable. If your workers speak mostly Spanish, an English-only video doesn't satisfy the standard ^[2].

Documentation matters. Keep records of who was trained, when, and what the training covered. There's no mandatory form, but if a compliance officer asks, you need proof. A sign-in sheet with the date, the topic, and a short outline of what was covered is the floor. For how training fits the wider compliance picture, the OSHA training overview covers the landscape.

One thing employers get wrong: a new chemical doesn't demand a full new session. A short documented briefing on the specific hazards, a pointer to the new SDS, and a check that workers understand the PPE can satisfy the standard, as long as you write it down.

What are the GHS pictograms and what do they mean?

The nine GHS pictograms are standardized symbols that appear on labels and sometimes on SDSs. Each stands for a hazard category ^[8]. Every small business owner should recognize all nine.

Pictogram	Hazard indicated
Flame	Flammable gases, liquids, solids, self-reactives, pyrophorics
Flame over circle	Oxidizers
Exploding bomb	Explosives, self-reactives, organic peroxides
Skull and crossbones	Acute toxicity (fatal or toxic)
Exclamation mark	Irritant, skin sensitizer, acute toxicity (harmful), narcotic effects
Health hazard (person with starburst)	Carcinogens, respiratory sensitizers, reproductive toxins, organ toxicity
Corrosion	Skin/eye corrosion, metal corrosion
Gas cylinder	Gases under pressure
Environment (dead tree and fish)	Aquatic toxicity (not enforced by OSHA)

The signal word sits alongside the pictograms and tells you the severity. "Danger" flags the more severe hazard categories. "Warning" flags moderate ones. A product carrying a skull and "Danger" is a different animal from one carrying an exclamation mark and "Warning."

On labels, pictograms are red-bordered diamonds on a white background. On SDSs they may print in black and white. Either version is acceptable.

What are the penalties for HazCom violations?

OSHA classifies most HazCom violations as "serious" because failing to tell workers about chemical hazards creates a real chance of death or serious harm. As of January 2024, the maximum penalty for a serious violation is $16,131 per violation ^[4]. Willful or repeated violations reach $161,323 per violation.

In practice, OSHA runs a gravity-based penalty calculation that can shrink fines for smaller employers with good-faith efforts and no prior history. But the starting point is real money, and multiple violations in one inspection stack fast. A small manufacturer with missing SDSs, unlabeled secondary containers, and no written program could face $30,000 to $60,000 in proposed penalties from a single visit.

HazCom is one of OSHA's most cited standards precisely because compliance is visible. An inspector walks your floor, asks a worker to find an SDS, grabs a random secondary container and asks about the label, and requests your written program, all in the first 20 minutes. No complex measurement required. That makes it an easy citation target.

For how inspections unfold and what inspectors want to see, the incident report guide covers documentation practices that shape enforcement visits.

How do you handle SDSs for chemicals brought in by contractors?

When a contractor brings hazardous chemicals into your facility, both of you carry obligations under 29 CFR 1910.1200(e)(2) ^[11]. The rule requires employers to inform contractors of any hazardous chemicals their employees might be exposed to while working in the facility. It also requires you to obtain SDSs for any hazardous chemicals the contractor brings in, and give your own employees access to them.

The practical move is to bake SDS exchange into contractor onboarding. Before work starts, ask for a list of every chemical the contractor will bring on site and an SDS for each. Keep those SDSs with your regular file system for the length of the project, and brief your workers on any new hazards.

This piece gets missed most on multi-employer sites. A painting contractor spraying solvent-based coatings in a space where your own workers are also present creates a chemical exposure for your employees. You can't manage what you don't know about. Get the SDSs before work starts, not after an exposure.

The requirement runs both ways. If your employees work at another employer's site and bring your chemicals along, you provide SDSs for those chemicals to the host employer.

What is the difference between an MSDS and an SDS?

MSDS stands for Material Safety Data Sheet, the old format used before OSHA aligned with GHS. SDSs replaced MSDSs after the 2012 HazCom revision. Manufacturers and importers had to have fully GHS-compliant SDSs in place by June 1, 2015. Employers had to update their workplaces, including training on the new format, by December 1, 2015, with full compliance expected by June 1, 2016 ^[6].

The practical difference is large. The old MSDS had no required structure. One MSDS might list flash point in section 3, another in section 7. No standardized order, no required signal words, no GHS pictograms. That made it harder for a worker under pressure to find what they needed.

The 16-section SDS is consistent across every product. Section 8 always covers exposure controls and PPE. Section 4 always covers first aid. That predictability pays off when something goes wrong and a worker or first responder needs information fast.

Still have old MSDS documents in your binder? Replace them. An MSDS is not compliant under current OSHA rules. Contact the manufacturer or check their website for a current SDS. Most major suppliers now run SDS portals you can search by product name.

How do state OSHA plans affect HazCom requirements?

Twenty-two states and two territories run their own OSHA-approved state plans covering private employers. These plans must be at least as effective as federal OSHA and can be stricter. Most have adopted a GHS-aligned HazCom standard essentially identical to federal 1910.1200, but a few add requirements ^[5].

California (Cal/OSHA) has its own Hazard Communication regulation at Title 8, Section 5194, which mirrors the federal rule but also requires employers with 10 or more employees to maintain a chemical inventory available to employees, beyond an SDS binder ^[9]. California also has Proposition 65, separate from HazCom, which affects how some products are labeled in the state.

States like Washington (L&I), Michigan (MIOSHA), and Oregon (OR-OSHA) run their own HazCom rules that are functionally equivalent to federal 1910.1200. If you operate in a state-plan state, confirm you're reading the right regulation. OSHA keeps a directory of approved state plans at osha.gov ^[5].

Frequently asked questions

Do I need an SDS for every chemical in my workplace, including common products like WD-40?

Yes, if a product is classified as hazardous under 29 CFR 1910.1200. WD-40 is a petroleum-based product that is flammable and has inhalation hazards, so it has an SDS and you should keep it on file. Consumer products used the way a consumer would use them at home are partially exempt, but if employees use them more often or in larger quantities, the exemption usually doesn't apply.

Can I keep SDSs on a computer or tablet instead of in a paper binder?

Yes. Electronic access is acceptable under 29 CFR 1910.1200(g)(8) as long as workers can reach SDSs at any time during their shift without a barrier. You need a reliable backup for when the network or device is down, and you must train workers on how to use the system. A locked-down terminal requiring an IT login, or a shared tablet that lives in a manager's office, fails the test.

How often do I need to update my SDSs?

OSHA sets no fixed update interval. Manufacturers and importers must issue a revised SDS within three months of learning of new significant health or safety information. Your job as an employer is to have the current SDS on file. A practical routine: check the binder annually and request fresh SDSs for any product where your copy runs more than three to five years old, or whenever you hear a formula changed.

What happens if a supplier can't provide an SDS for a product I buy?

You have two moves. First, contact the manufacturer directly, more than the distributor, and request the SDS in writing. Second, if the manufacturer truly can't provide one, don't use the product until you have an SDS. Using a chemical whose hazards are unknown violates the HazCom standard. Document your attempts to get the SDS in case OSHA asks.

Do I need to train existing employees again when I introduce a new chemical?

Yes, but it doesn't have to be a formal classroom session. Inform affected workers of the new chemical's hazards before they work with it, point them to the new SDS, and confirm they understand the required PPE and handling steps. Document what was covered and who attended. A short tailgate or toolbox talk with a sign-in sheet satisfies this in most situations.

Are there chemicals that are exempt from the HazCom standard?

Yes. 29 CFR 1910.1200(b)(6) lists exemptions including hazardous waste regulated under RCRA, tobacco products, wood and wood products in their natural state, foods and beverages for employee consumption, drugs in solid final form for direct administration, consumer products used the same way a consumer would, and ionizing and non-ionizing radiation. The exemptions are narrow. When in doubt, treat a chemical as covered.

What does the GHS signal word 'Danger' versus 'Warning' mean on a label?

'Danger' marks the more severe hazard categories within a classification. 'Warning' marks less severe ones. If a product's hazards would call for both (say, two different hazards, one warranting Danger and one Warning), only 'Danger' appears on the label. The signal word always sits on the label, never as an SDS section heading.

Do I need a separate written HazCom program or can it be part of my overall safety program?

It can be part of a broader written safety program. OSHA requires the HazCom program to be written and available to employees and OSHA representatives on request, but doesn't demand a stand-alone document. Many small businesses fold the HazCom program into their safety manual as a chapter. What matters is that it specifically addresses labels, SDS access, and training as applied to your actual workplace.

How do I handle a hazardous chemical that has no SDS because it was made in-house or blended on site?

If your operation creates a hazardous chemical, you're the manufacturer for HazCom purposes. You evaluate the hazards of that chemical and prepare a compliant label and SDS. This covers blended products, mixed solutions, and anything your facility produces that workers may be exposed to. Use OSHA's guidance in Appendix A and B to 1910.1200 to classify the hazards.

What is OSHA's National Emphasis Program on chemical hazards and how does it affect me?

OSHA periodically runs National and Local Emphasis Programs (NEPs and LEPs) targeting specific hazards, including chemical exposure. These programs direct compliance officers to inspect targeted industries proactively rather than wait for complaints. If your industry is targeted, expect a possible unannounced inspection where HazCom compliance gets scrutinized alongside the specific chemical hazard driving the NEP. Check OSHA's website for active emphasis programs in your industry.

How long do I have to keep SDSs for chemicals I no longer use?

OSHA's HazCom standard sets no retention period for discontinued chemicals. But 29 CFR 1910.1020 requires employers to keep employee exposure records for 30 years. OSHA has taken the position in letters of interpretation that SDSs for chemicals workers were exposed to fall under that 30-year rule. Archive old SDSs separately from your active binder, clearly labeled by the years they were in use.

Can OSHA cite me for a chemical hazard I didn't know about?

Yes, with a qualification. OSHA's general duty clause, Section 5(a)(1) of the OSH Act, allows citations for recognized hazards even without a specific standard. For HazCom, not knowing a chemical was in your workplace isn't a defense if a reasonable employer would have known. The standard requires you to keep an inventory of hazardous chemicals, which means you're expected to know what's there.

Are small businesses (under 10 employees) exempt from HazCom?

No. The HazCom standard at 29 CFR 1910.1200 applies to any employer with at least one employee who uses, handles, or could be exposed to hazardous chemicals. There is no size-based exemption. Some OSHA paperwork rules have small-employer carve-outs, but HazCom is not one of them. The written program, SDS maintenance, labels, and training all apply no matter how many people you employ.

What is an SDS product identifier and why does it matter?

The product identifier in Section 1 of an SDS is the name or number that links the SDS to the label on the container. It must match. If your label says 'Industrial Degreaser Formula 7' and your SDS says 'Formula 7 Industrial Degreaser,' that's close enough in practice, but if a compliance officer can't trace a container to its SDS, you have a documentation problem. Consistent naming across inventory, labels, and binder prevents confusion and citations.

Sources

1. OSHA, Top 10 Most Frequently Cited Standards FY2023: Hazard Communication (1910.1200) was the number two most-cited OSHA standard in fiscal year 2023 with 2,179 violations.
2. OSHA, 29 CFR 1910.1200 Hazard Communication Standard: The standard requires 16-section SDSs, compliant labels, a written program, employee training before first exposure, no-barrier SDS access during the shift, and training in a language workers understand.
3. OSHA, Penalties (civil monetary penalty adjustments): As of January 2024, the maximum penalty for a serious OSHA violation is $16,131 per violation; willful or repeated violations can reach $161,323 per violation.
4. OSHA, State Plans (directory of approved state plans): Twenty-two states and two territories run OSHA-approved state plans that must be at least as effective as the federal standard and may be more stringent.
5. OSHA, 29 CFR 1910.1020 - Access to Employee Exposure and Medical Records: Employers must retain employee exposure records, including records of chemical exposures, for 30 years; OSHA letters of interpretation have extended this to SDSs for chemicals in use during that period.
6. United Nations Economic Commission for Europe, Globally Harmonized System of Classification and Labelling of Chemicals (GHS): The GHS defines nine pictograms, two signal words (Danger and Warning), and standardized hazard and precautionary statement texts used in the 16-section SDS format.
7. OSHA, 29 CFR 1910.1200(e)(2) - Contractor obligations under the written program: Under 29 CFR 1910.1200(e)(2), employers must inform contractors of hazardous chemicals on site and obtain SDSs for chemicals contractors bring into the facility.
8. OSHA, Appendix D to 1910.1200 - Minimum Information for an SDS: Appendix D to 1910.1200 specifies all 16 required SDS sections in mandatory order; sections 1-11 and 16 are enforced by OSHA; sections 12-15 are required in the document but not directly enforced.