What the hazard communication standard includes: every requirement explained

Last updated 2026-07-10

What is the Hazard Communication Standard and who does it apply to?

The Hazard Communication Standard, codified at 29 CFR 1910.1200, is OSHA's rule that makes employers tell workers about the hazardous chemicals in their workplaces. ^[1] Here is the short version. If a chemical can hurt someone, every person who might touch it, breathe it, or work near it has a right to know what it is and what to do about it.

The rule reaches almost every employer in general industry, construction, maritime, and agriculture where hazardous chemicals are present. That is a very wide net. A small auto body shop with paint stripper and solvents is covered. A restaurant supply company with cleaning chemicals is covered. A concrete crew mixing Portland cement is covered. The standard says: "This section requires chemical manufacturers or importers to classify the hazards of chemicals which they produce or import, and all employers to provide information to their employees about the hazardous chemicals to which they are exposed." ^[1]

Manufacturers, importers, and distributors carry extra duties: they classify chemicals and produce the hazard information. Employers who only use chemicals (downstream users) have to pass that information along and train their people.

Hazcom, as most people call it, has landed near the top of OSHA's citation list for years. In fiscal year 2023 it produced 3,213 violations, the second most cited standard of any kind. ^[2] That volume tells you how often employers get the details wrong.

What are the six main components of the Hazard Communication Standard?

The hazard communication standard includes six elements, and this is the question most people are really asking:

1. A written hazard communication program 2. A chemical inventory (list of hazardous chemicals) 3. Safety Data Sheets (SDSs) 4. Container labels 5. Employee training 6. Trade secret provisions

Each one is a separate requirement with its own rules. Miss any single component and that is a citable violation on its own, even if the other five are perfect. Here is what each one actually demands.

Written Hazard Communication Program This is a site-specific document that describes how your workplace meets the whole standard. It spells out how you handle SDSs, how you label containers, and how you train people. Workers get to see it on request. A downloaded template can work, but only after you add your company name, attach your chemical list, and fill in your real procedures. A blank template in a drawer does not comply.

Chemical Inventory You need a list of every hazardous chemical in your workplace. No minimum quantity triggers this. If the chemical is hazardous and employees may be exposed, it goes on the list. The inventory ties straight to your SDSs: every chemical on the list needs a matching SDS.

Safety Data Sheets SDSs are the 16-section standardized documents that lay out a chemical's physical and health hazards, safe handling steps, PPE, and emergency response. You must have one for every hazardous chemical. They have to be reachable during every work shift, which in practice means posted, in a binder near the work area, or on a computer employees can actually get to without walking to a back office and asking a supervisor.

Container Labels Every container of a hazardous chemical needs a GHS label: product name, signal word (Danger or Warning), hazard statements, precautionary statements, GHS pictograms, and the supplier's name and address. You cannot remove or deface original labels. For in-plant transfer containers (a smaller spray bottle filled from a drum, say), OSHA allows a simpler label as long as it names the chemical and gives basic hazard information.

Employee Training Workers get trained before their first assignment to any area where hazardous chemicals are present. Training covers what SDSs are and how to read them, how to read labels and pictograms, the specific chemicals in their area, how to detect a release, the physical and health hazards, and what protective measures to use. Training at hire is required. Retraining when new chemicals show up is expected.

Trade Secret Provisions Manufacturers can withhold a specific chemical identity from an SDS when it qualifies as a trade secret. They cannot hide that a hazard exists, and they must disclose the identity to health professionals who need it for diagnosis or treatment. ^[1] This rarely touches downstream employers, but it is technically part of the standard.

How does the GHS fit into OSHA's Hazard Communication Standard?

In 2012, OSHA rewrote the Hazard Communication Standard to line it up with the Globally Harmonized System of Classification and Labelling of Chemicals (GHS). ^[3] That rewrite is why the standard looks the way it does today. Standardized 16-section SDSs replaced the old MSDSs. Pictograms became standardized. Two signal words (Danger and Warning) replaced the patchwork of language that came before.

The GHS does not replace the standard. It is the framework the standard runs on, the international language OSHA adopted. GHS sets the hazard classification criteria, the nine pictograms (flame, exclamation mark, skull and crossbones, health hazard, corrosion, environment, gas cylinder, exploding bomb, and flame over circle), and the structure of labels and SDSs. ^[8]

The full transition deadline passed June 1, 2016. Every SDS should be in the 16-section format now, and every label should carry GHS pictograms. If a supplier still ships you old MSDSs, that supplier is breaking their own obligations. Push them, or find a supplier who complies.

One practical note. The 16 SDS sections in order are (1) identification, (2) hazard identification, (3) composition and information on ingredients, (4) first-aid measures, (5) fire-fighting measures, (6) accidental release measures, (7) handling and storage, (8) exposure controls and PPE, (9) physical and chemical properties, (10) stability and reactivity, (11) toxicological information, (12) ecological information, (13) disposal considerations, (14) transport information, (15) regulatory information, and (16) other information. Sections 1 through 11 are the ones employers and workers actually use most.

What must a written hazard communication program include?

The written program is the spine that holds everything else in place. 29 CFR 1910.1200(e) says exactly what it has to address. ^[1]

Four things. It describes how your workplace handles each element of the standard: labeling, SDSs, and training. It explains how employees get access to SDSs. It includes the chemical inventory, attached or referenced. And it covers non-routine tasks that involve hazardous chemicals (a maintenance crew cleaning a tank, for example) plus how you communicate hazards to contractors working in your facility.

The contractor piece trips up a lot of small employers. If an outside cleaning crew comes in at night with chemicals, you have two jobs: tell them about the hazards in your facility that could reach them, and know about the chemicals they bring in. Both sides exchange SDS access. Not optional.

The program has to be written. An oral understanding between the owner and the one employee does not count. A two-page document that describes your real procedures beats a 40-page consultant template that does not match how you work. Inspectors look for a document that is real and used, not printed and filed. If you want a fast start, the SafetyFolio program generator builds a site-specific written program in about 15 minutes from your actual chemical list.

What the standard does not require: a set length, a fancy format, or a consultant's signature. Plain language that matches your workplace is fine.

What are the SDS requirements under the Hazard Communication Standard?

Safety Data Sheets are the detailed hazard documents for individual chemicals, and they sit at the center of the whole system. The rules split into three parts: who prepares them, what they contain, and how employers manage them.

Manufacturers and importers prepare an SDS for every hazardous chemical they produce or import. ^[1] Employers who use chemicals do not write SDSs. They obtain them, keep them current, and make them reachable.

Getting SDSs: Most suppliers include them with shipments or post them online. If you do not get one, you are entitled to ask. A supplier who refuses to provide an SDS for a hazardous chemical is breaking the standard. Document your request.

Keeping them current: Your SDSs have to reflect current hazard data. When a supplier sends a revised sheet, swap out the old one. Do more than toss it on a pile.

Accessibility: This is where employers get cited. SDSs must be readily accessible to employees during their work shift. ^[1] "Readily accessible" means reachable without a supervisor's permission and without delay. A binder in the break room is fine. A locked file cabinet in the manager's office is not. Electronic systems are allowed if you have a backup for power outages and employees can actually use the system.

You do not need paper for every chemical if your system is electronic. You do need a reliable backup plan, and workers have to be trained on the system.

For a real SDS in use, see our article on the hcl safety data sheet.

What do GHS labels on containers need to include?

A GHS label under the Hazard Communication Standard needs six elements. ^[1] Miss one and the label does not comply.

1. Product identifier: The name or number that matches the SDS. 2. Signal word: Either "Danger" (more severe hazards) or "Warning" (less severe). Not both. Not a made-up word. 3. Hazard statements: Short phrases describing each hazard ("Causes serious eye damage," for example). 4. Precautionary statements: How to prevent harm, respond when something goes wrong, store the chemical, and dispose of it. 5. Pictograms: The relevant GHS symbols in a red diamond border. 6. Supplier information: The manufacturer's or importer's name, address, and phone number.

For in-house containers like a spray bottle filled from a drum, OSHA lets you use a workplace label that skips the supplier information, as long as it carries the product identifier and enough words and pictograms to warn workers clearly. The simpler format is fine because workers can go to the SDS for full detail.

Here is what catches employers. Transfer a chemical into an unlabeled container, and if that same worker uses it immediately and never leaves it, the portable container exemption applies. But if the container sits overnight, lands on a shelf, or could get used by anyone else, it needs a label. The "immediate use" exemption is narrower than most people think.

What does Hazard Communication Standard training need to cover?

29 CFR 1910.1200(h) lists what training has to cover. ^[1] The standard gives you room on format (video, classroom, one-on-one) but none on content.

Training must address:

• The requirements of the HazCom standard itself and the employer's written program
• Operations in the employee's work area where hazardous chemicals are present
• Where and how to access the written program, chemical inventory, and SDSs
• How to read labels, including pictograms and signal words
• How to read and use an SDS
• Physical, health, simple asphyxiation, combustible dust, and pyrophoric hazards
• How to detect a release of hazardous chemicals (odor, color change, monitoring instruments)
• Protective measures: engineering controls, work practices, and PPE

Timing matters too. Training happens before the employee's first assignment in an area where hazardous chemicals are present. Not during the first week. Before the first exposure. New chemicals trigger more training.

OSHA does not set a required duration or a test, but inspectors will ask employees what they know. If a worker cannot say what the skull-and-crossbones pictogram means, or cannot find the SDSs, the training on paper counts for little during an inspection.

For a wider look at OSHA training rules, see our guide to osha training. If you want a formal credential, the osha 30 course covers HazCom in depth as part of the general industry curriculum.

What hazard classifications does the standard use?

Under the GHS-aligned HazCom standard, hazards fall into two families: physical hazards and health hazards. Each family has specific classes, and within those classes, specific categories (numbered 1, 2, 3, and so on, with 1 almost always the most severe).

Physical hazard classes include flammables, explosives, oxidizers, compressed gases, self-reactive chemicals, pyrophorics, self-heating chemicals, chemicals that emit flammable gases in contact with water, organic peroxides, and corrosive to metals.

Health hazard classes include acute toxicity, skin corrosion and irritation, serious eye damage and irritation, respiratory or skin sensitization, germ cell mutagenicity, carcinogenicity, reproductive toxicity, specific target organ toxicity (single exposure), specific target organ toxicity (repeated exposure), and aspiration hazard.

The standard adds two more categories: simple asphyxiants (gases that displace oxygen, like nitrogen or carbon dioxide in enclosed spaces) and combustible dust.

This system matters because it decides which pictograms hit the label, which signal word applies, and how the hazard and precautionary statements read. It also shapes what training workers need. A carcinogen calls for different precautions and a different level of concern than a mild skin irritant, and the SDS and label will show it.

Most downstream employers do not classify chemicals themselves. The classification comes from the manufacturer and lives in Section 2 of the SDS. Your job is to understand what those classifications mean so you can train workers and pick the right controls.

How does the Hazard Communication Standard apply to construction and small businesses?

The construction version lives at 29 CFR 1926.59, but it just incorporates 29 CFR 1910.1200 by reference. ^[4] The requirements are identical. A framing contractor who uses treated lumber, adhesives, and concrete is covered the same as a manufacturing plant.

Small businesses stumble in three predictable places: the written program (missing or generic), the chemical inventory (outdated or incomplete), and SDS access (files locked up or impossible to find on a job site). The cost of fixing all three is low. Time to write the program, discipline to collect and organize SDSs, and a training session that does not have to be elaborate.

OSHA's free HazCom compliance help page includes a model written program and other tools. ^[1] You do not need a consultant to comply with this standard. You need a couple of focused hours and a system you keep up.

One honest note on small business reality. The requirements are the same whether you have 3 employees or 3,000. There is no small-employer exemption. The practical difference is that a solo operator can knock out a compliance check in a single afternoon, while a multi-site manufacturer needs more infrastructure. The paperwork does not scale with headcount. The management system does.

What are the most common Hazard Communication Standard violations OSHA cites?

HazCom was the second most cited standard in OSHA's FY2023 data, with 3,213 total violations across all industries. ^[2] The specific violations cluster in a few spots.

Missing or inaccessible SDSs is the biggest driver, every year. An inspector walks in, asks an employee to show the SDS for a chemical they use daily, and the employee cannot. Sometimes it is locked in an office. Sometimes it never existed for that chemical. Sometimes it exists but it is a 2009 MSDS in the old format.

The written program is second, usually because it does not exist or it is a generic template that nobody adapted to the workplace. An inspector can tell in a minute when a program does not describe the real place.

Labeling violations show up in facilities that repackage or transfer chemicals into smaller containers and skip the label. The "immediate use" exemption is real but narrow, and employers stretch it too far.

Training violations surface in worker interviews. If three employees in a row cannot say what to do in a chemical spill or cannot find the SDSs, that is evidence of bad training no matter what the records say.

HazCom penalties in 2024 reach $16,131 for each serious violation, and willful or repeat violations run up to $161,323 each. OSHA adjusts these figures every year for inflation under the Federal Civil Penalties Inflation Adjustment Act. ^[6] A facility with dozens of unlabeled containers or no written program stacks up a large penalty fast.

See our broader hazard communication guide for how to audit your program before an inspector does.

How does the Hazard Communication Standard interact with other OSHA rules?

HazCom does not stand alone. Several other OSHA standards overlap with it, and knowing the connections helps you avoid gaps.

Process Safety Management (29 CFR 1910.119): PSM applies to highly hazardous chemicals above specific threshold quantities. HazCom covers all hazardous chemicals; PSM piles on a much deeper set of requirements for the worst actors. If you have ammonia, chlorine, or flammable liquids above PSM thresholds, HazCom is necessary but not enough. ^[7]

Respiratory Protection (29 CFR 1910.134): When an SDS flags inhalation as a hazard and engineering controls fall short, you need a respiratory protection program. The SDS tells you what PPE is needed. The respiratory protection standard tells you how to manage it.

PPE (29 CFR 1910.132): Section 8 of every SDS covers exposure controls and personal protective equipment. That feeds straight into your PPE hazard assessment. The two standards work together.

Lockout/Tagout (29 CFR 1910.147): During maintenance on equipment that holds hazardous chemicals, lockout tagout procedures and HazCom both apply. Workers need to know the chemical hazards before they open a pipe or vessel.

That is the reality of OSHA compliance. No single standard is an island. A solid osha training program covers these overlaps out loud so workers understand how the rules fit together.

What does OSHA require for multi-employer worksites under HazCom?

Multi-employer worksites, common in construction and facility maintenance, create a specific HazCom duty that many employers underestimate.

29 CFR 1910.1200(e)(2) requires that an employer who produces, uses, or stores hazardous chemicals in a workplace where other employers' employees may be exposed provide those other employers with SDSs and precautionary information for those chemicals. ^[1] Two-way street. You tell contractors about your chemicals. You find out about theirs.

In practice, before a subcontractor starts work at your facility, you exchange chemical lists and SDS access. You tell them where your hazardous chemicals sit, what they are, and any site-specific controls. They tell you what they are bringing in and hand over SDSs.

The general contractor usually carries the primary coordination duty, but subcontractors stay independently responsible for their own employees' HazCom training. OSHA's multi-employer citation policy spells out how those responsibilities divide. ^[11]

This is the provision most general contractors handle badly. A pre-job safety meeting that includes a chemical review is the practical fix. It does not have to be elaborate. It does have to happen, and it has to be documented.

If your company files reports when near misses or injuries involve chemical exposure, the incident report process should capture the SDS reference and exposure details, which loops right back to HazCom documentation.

How can a small business build a compliant HazCom program quickly?

Here is the honest sequence. None of it needs a consultant.

Step 1: Walk every area and list every hazardous chemical. Cleaning products, lubricants, paints, solvents, adhesives, fuels, battery acid. If you are unsure whether something is hazardous, look it up or request an SDS from the supplier. The SDS tells you.

Step 2: Collect an SDS for every chemical on your list. Most live on supplier websites. Keep them in one place, reachable on every shift.

Step 3: Write your hazard communication program. It does not have to be long. It does have to describe how your workplace handles SDSs, labels, training, and contractors. Attach the chemical inventory.

Step 4: Check every container label. Every container needs at least the product name and basic hazard information. In-house transfer containers need labels if anyone but the person who filled them might use them.

Step 5: Train employees before they work with or near hazardous chemicals. Cover what the chemicals are, where to find SDSs, how to read labels and pictograms, and what to do when something goes wrong. Keep a training record.

Step 6: Review when anything changes. New chemical comes in, train on it. SDS gets updated, file the new version. New employee starts, train before day one.

To compress Steps 1 through 3, the SafetyFolio program generator walks you through a 15-minute process to produce a written HazCom program tailored to your workplace.

The whole system needs a periodic look. Chemicals change. Suppliers send updated SDSs. New products arrive. An annual review of the chemical inventory and the program is a reasonable floor for most small businesses.

Frequently asked questions

The hazard communication standard includes which of the following: labels, SDSs, training, or all of the above?

All of the above, plus more. The hazard communication standard (29 CFR 1910.1200) includes six elements: a written hazard communication program, a chemical inventory, Safety Data Sheets, GHS container labels, employee training, and trade secret provisions. All six are mandatory. An employer with labels and SDSs but no written program or no training still has citable violations.

What is the purpose of the Hazard Communication Standard?

The purpose is to make sure employers and employees know the hazards of chemicals in the workplace and how to protect themselves. OSHA often calls it a "right to know" law. Chemical manufacturers classify hazards. Employers pass that information to workers through labels, SDSs, and training before exposure occurs.

How many sections does a Safety Data Sheet have under HazCom?

A GHS Safety Data Sheet has exactly 16 sections, in a standardized order. They cover product identification, hazard identification, composition, first aid, firefighting, spill response, handling and storage, exposure controls and PPE, physical and chemical properties, stability, toxicology, ecology, disposal, transport, regulatory information, and other information. Sections 1 through 11 hold the health and safety data most workers use day to day.

What are the GHS pictograms and what does each one mean?

There are nine GHS pictograms: flame (flammable), flame over circle (oxidizer), exploding bomb (explosive or reactive), gas cylinder (gases under pressure), corrosion (skin or metal corrosion), skull and crossbones (acute toxicity), exclamation mark (irritant, harmful, or narcotic), health hazard (carcinogen, mutagen, sensitizer, reproductive toxin, or organ toxicity), and environment (aquatic toxicity). Each sits in a red diamond on GHS labels.

Does the Hazard Communication Standard apply to small businesses with only a few employees?

Yes. There is no small-employer exemption in 29 CFR 1910.1200. A business with two employees that uses cleaning chemicals or solvents needs a written program, SDSs, compliant labels, and trained employees. The paperwork is lighter with fewer chemicals, but the legal requirement matches what a large manufacturer faces.

What is the difference between an MSDS and an SDS?

Material Safety Data Sheets (MSDSs) were the old format required before OSHA's 2012 HazCom revision. Safety Data Sheets (SDSs) are the GHS-aligned 16-section replacement. All SDSs had to be in the new format by June 1, 2016. The content is similar, but the SDS uses a standardized section order and language, so workers find specific information faster.

When does an employee need to be trained under the Hazard Communication Standard?

Before their first assignment to a work area where hazardous chemicals are present. Not during the first week. Not within 30 days. Before the first potential exposure. More training is required when new chemicals enter the work area. OSHA sets no required format or test, but inspectors interview workers to confirm the training content actually landed.

Does the Hazard Communication Standard require training records to be kept?

The standard does not set a record retention period for HazCom training, but inspectors routinely ask for records. Keep signed records with dates and topics covered. If you cannot document that training happened, an inspector may treat it as if it did not. Holding records for at least three years is a reasonable practice, in line with other OSHA recordkeeping.

What is the "immediate use" exemption for container labels?

Under 29 CFR 1910.1200(f)(8), a portable container filled from a labeled container by the employee who intends to use it immediately and only during that shift does not need a separate label. The exemption is narrow: that employee, that shift, that immediate use. Set the container down, store it, or hand it to someone else, and it needs a label. Employers stretch this too far and get cited.

How does the Hazard Communication Standard handle trade secrets?

Manufacturers can withhold the specific identity of a hazardous ingredient from an SDS if it qualifies as a trade secret, but they must still disclose all hazard information and cannot hide that a hazard exists. They must give the chemical identity to health professionals, emergency responders, and physicians who need it for diagnosis or treatment. Employers using such chemicals must make all available hazard information accessible to workers.

Can I use electronic SDSs instead of paper binders?

Yes. OSHA allows electronic SDS systems under three conditions: employees can access SDSs during their work shift without supervisor permission, there is a reliable backup for power or computer failures, and employees are trained on the system. A system locked behind a manager login, or one with no offline backup, fails the "readily accessible" requirement.

What is the Hazard Communication Standard citation penalty in 2024?

For 2024, OSHA's maximum penalty for a serious HazCom violation is $16,131 per violation. Willful or repeat violations reach $161,323 each. OSHA adjusts these figures every year for inflation under the Federal Civil Penalties Inflation Adjustment Act. A single inspection at a facility with multiple HazCom deficiencies can produce several separate violations, each with its own penalty.

What is the difference between a physical hazard and a health hazard under HazCom?

Physical hazards come from the chemical's physical properties: flammability, reactivity, explosivity, oxidizing potential. Health hazards come from effects on the body: acute toxicity, carcinogenicity, skin corrosion, organ toxicity. Both categories have to appear on SDSs and labels. A single chemical can carry both, like a flammable solvent that is also an acute toxin.

How does the Hazard Communication Standard define a hazardous chemical?

29 CFR 1910.1200 defines a hazardous chemical as "any chemical which is classified as a physical hazard or a health hazard, a simple asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise classified." The classification comes from the manufacturer. If a chemical has an SDS with any hazard classification in Section 2, it counts as hazardous for HazCom and belongs on your inventory.

Sources

1. OSHA, 29 CFR 1910.1200 Hazard Communication Standard: Full text of the HazCom standard including all six required elements: written program, chemical inventory, SDSs, labels, training, and trade secret provisions
2. OSHA, Top 10 Most Cited Standards FY2023: Hazard Communication ranked second most cited standard in FY2023 with 3,213 violations
3. OSHA, Hazard Communication: Aligning with the Globally Harmonized System (GHS): OSHA revised HazCom in 2012 to align with the UN Globally Harmonized System; full transition deadline was June 1, 2016
4. OSHA, 29 CFR 1926.59 Hazard Communication (Construction): Construction standard incorporates 29 CFR 1910.1200 by reference, making HazCom requirements identical in construction
5. OSHA, Penalties: Maximum penalty for serious violations in 2024 is $16,131 per violation; willful or repeat violations up to $161,323
6. OSHA, 29 CFR 1910.119 Process Safety Management: PSM applies to highly hazardous chemicals above threshold quantities, adding requirements beyond HazCom
7. OSHA, GHS Pictograms and Hazard Classes: Nine GHS pictograms defined, each representing specific hazard classes and categories
8. United Nations Economic Commission for Europe, Globally Harmonized System of Classification and Labelling of Chemicals (GHS): GHS defines hazard classification criteria, 16-section SDS format, pictograms, and signal word requirements adopted by OSHA
9. OSHA, Multi-Employer Citation Policy Directive CPL 02-00-124: OSHA policy on multi-employer worksite obligations including HazCom information exchange between employers