What the hazard communication standard requires: a plain-language guide

Last updated 2026-07-09

What is the hazard communication standard, exactly?

The Hazard Communication Standard, written into 29 CFR 1910.1200, is OSHA's right-to-know rule. It gives workers the right to know about the hazardous chemicals they handle. ^[1] People call it HazCom 2012 because OSHA rewrote it in 2012 to line up with the United Nations Globally Harmonized System of Classification and Labelling of Chemicals (GHS). General industry uses 29 CFR 1910.1200; construction uses 29 CFR 1926.59. Both run on the same GHS framework. ^[1]

The rule covers any chemical that is a physical hazard (flammable, explosive, reactive) or a health hazard (toxic, carcinogenic, corrosive, or similar). OSHA's 2012 rewrite spelled out those hazard categories so that a chemical gets classified the same way whether it comes from a manufacturer, a supplier, or a distributor. ^[1]

HazCom lands near the top of OSHA's citation list almost every year. In fiscal year 2023 it was the second most-cited standard across all industries, with more than 3,200 violations recorded. ^[2]

That number is not a fluke. Small businesses get cited hard because the rule sounds simple until you sit down to document all of it.

If you want the bigger picture on how OSHA enforcement works, read our overview of OSHA first, then come back for the specifics.

What does 29 CFR 1910.1200 specifically require employers to do?

Five things. Every employer with hazardous chemicals in the building has to do all five, and there are no small-business exemptions.

1. Written Hazard Communication Program. You need a written document that explains how your company meets each piece of the standard: how you handle labels, where SDSs live, and how you train workers. ^[1] The written program also has to list every hazardous chemical in the workplace or point to where that list is kept.

2. Chemical Inventory. A complete list of every hazardous chemical on site. OSHA does not dictate a format. A spreadsheet is fine. The inventory ties each chemical to its SDS.

3. Safety Data Sheets (SDS). You have to obtain an SDS for every hazardous chemical you use and keep those sheets reachable during every shift. ^[1] Reachable means a worker can get to them without asking a supervisor, without a password only a manager has, and without waiting.

4. Labeling. Every container of a hazardous chemical carries a GHS label with the product identifier, signal word (Danger or Warning), hazard statements, pictograms, precautionary statements, and supplier information. ^[1] Pour a chemical into a smaller container for use in your facility and that secondary container needs a label too, unless the worker who fills it uses it right away and keeps it in hand the whole time.

5. Employee Training. Workers get trained before they start working with hazardous chemicals, and again whenever a new hazard shows up. ^[1] The standard says exactly what that training covers, and we walk through it below.

The rule also tells manufacturers and importers to classify and label the chemicals they produce, but most small businesses are downstream users, not makers. So the inventory, the SDSs, the labels, the written program, and the training are where your work actually goes.

What must a GHS-compliant label include?

A GHS label has six required elements under 29 CFR 1910.1200(f). ^[1] Every one of them has to appear on a shipped container. Miss one and the label is not compliant.

Label Element	What It Is
Product identifier	The chemical name or code that matches the SDS
Signal word	Either "Danger" (more severe) or "Warning" (less severe)
Hazard statements	Standard phrases describing the hazard (e.g., "Causes serious eye damage")
Precautionary statements	What to do to prevent or reduce harm
Pictograms	One or more of the nine GHS pictograms in a red diamond border
Supplier information	Name, address, and phone number of the manufacturer or importer

The nine GHS pictograms cover health hazard, flame, exclamation mark, gas cylinder, corrosion, exploding bomb, flame over circle (oxidizer), skull and crossbones, and environment. OSHA does not require the environmental pictogram in the U.S., but it shows up anyway because many manufacturers print the international GHS format. ^[1]

For workplace containers (secondary containers), you can run a simpler system like NFPA diamonds or HMIS ratings, as long as your written program explains the system and your training covers it. That shortcut stops at your door. Shipped containers still need the full GHS label.

There is no single mandatory HazCom poster. What OSHA does require is the general "Job Safety and Health: It's the Law" poster (OSHA 3165) in every covered workplace. ^[3] Plenty of employers hang a supplemental HazCom notice near chemical storage that points workers to where the SDSs are. That is good practice, not a separate legal requirement.

What are the 16 sections of a Safety Data Sheet and what does each one contain?

OSHA's 2012 rewrite standardized the SDS. Every SDS has exactly 16 sections in exactly this order. ^[1] That fixed the old Material Safety Data Sheet (MSDS) format, which had no required structure and left every manufacturer to do its own thing.

Section	Title	Key Content
1	Identification	Product name, manufacturer, intended use, emergency phone
2	Hazard(s) identification	GHS classification, signal word, pictograms, hazard and precautionary statements
3	Composition / ingredients	Chemical identity and CAS number; trade secrets can be claimed
4	First-aid measures	What to do for inhalation, skin contact, eye contact, ingestion
5	Fire-fighting measures	Suitable extinguishing media, special hazards, PPE for firefighters
6	Accidental release measures	Spill cleanup procedures, containment
7	Handling and storage	Safe handling practices, storage conditions
8	Exposure controls / PPE	OSHA PELs, ACGIH TLVs, required PPE
9	Physical and chemical properties	Flash point, boiling point, vapor pressure, etc.
10	Stability and reactivity	Conditions to avoid, incompatible materials
11	Toxicological information	Routes of exposure, symptoms, carcinogenicity data
12	Ecological information	(Not enforced by OSHA)
13	Disposal considerations	(Not enforced by OSHA)
14	Transport information	(Not enforced by OSHA)
15	Regulatory information	Other applicable regulations
16	Other information	Date of preparation, revision date

Sections 12 through 15 have to be present, but OSHA does not enforce their content because those areas belong to EPA, DOT, and international authorities. ^[1] The sections still need to exist. They can read "not applicable" without earning you a citation.

Hydrochloric acid comes up constantly in training examples. To see how a real SDS reads for a common lab and industrial chemical, our breakdown of the hcl safety data sheet walks all 16 sections with notes.

SDSs have to be available in English. If some of your workers have limited English, OSHA does not require SDSs in other languages, but your training still has to make sure those workers understand the hazards. In practice that often means translated handouts on top of the English SDS.

What does hazard communication training have to cover?

Training is where small businesses fall down. A binder full of SDSs is not training. The standard wants workers who actually understand the hazards, not a signature on a sign-off sheet. ^[1]

29 CFR 1910.1200(h) says training has to cover: ^[1]

• The requirements of the HazCom standard and how to reach the written program
• Where the chemical inventory and SDSs are kept
• How to detect the presence or release of hazardous chemicals (odor, visual signs, monitoring)
• The physical, health, and other hazards of the chemicals in the work area
• Protective measures: engineering controls, work practices, and PPE
• How to read and use labels and SDSs

OSHA sets no minimum hours. The standard requires training at the time of initial assignment and again whenever a new physical or health hazard enters the work area. ^[1] That second trigger trips people up. Bring in a solvent you have never stocked before and your existing crew needs training on it before they use it, even if they sat through general HazCom last year.

Format is up to you. Classroom sessions, online modules, toolbox talks, one-on-one instruction, all fine. What matters is that the training points at the actual chemicals in your building. A generic online chemical-safety video that never names your products probably does not satisfy the standard on its own.

Documentation is not spelled out in 1910.1200, but a compliance officer will ask for proof training happened. Keep a training log with dates, employee names, topics covered, and the trainer's name. Skip it and you are one inspection away from a citation you cannot fight.

For how training fits across other OSHA standards, see our guide to osha training.

What must a written hazard communication program include?

The written program is the document that holds everything together. 29 CFR 1910.1200(e) says it has to cover three areas. ^[1]

1. Labels and other forms of warning. Your program describes how you make sure containers are labeled, what system you use for secondary containers, and how you handle unlabeled pipes and piping systems.

2. Safety Data Sheets. The program says how you obtain SDSs (usually from suppliers), where you keep them, and how workers reach them. It also spells out what happens when a chemical shows up with no SDS. The answer: you call the supplier and nobody uses the chemical until you have one.

3. Employee information and training. The program describes when training happens, who runs it, and how you confirm workers understood it.

The program also lists every hazardous chemical on site or points to a separate inventory. A company with multiple work areas can run one written program as long as it covers every location. Contractors are responsible for their own workers, but 29 CFR 1910.1200(e)(2) requires you to hand your SDSs to a contractor's workers and warn contractors about hazards they might hit. ^[1]

OSHA posts a sample written HazCom program on its site. It is a fine starting point and it is generic. The real work is loading it with your actual chemical inventory and your specific procedures.

If you want a compliant written program without starting from a blank page, SafetyFolio's safety program generator builds a HazCom-ready written program from your workplace inputs in about 15 minutes.

One honest note. The written program is the first thing a compliance officer asks for during an inspection. Cannot produce it on the spot? That is a separate citation from whatever else they find.

Which industries does the hazard communication standard apply to?

Almost all of them. The general industry standard at 29 CFR 1910.1200 covers any general-industry workplace where employees may be exposed to hazardous chemicals. Construction runs under 29 CFR 1926.59, which adopts the general-industry HazCom requirements wholesale. Maritime work (shipyards, marine terminals, longshoring) falls under 29 CFR 1915, 1917, and 1918. ^[1]

HazCom started small. When it launched in 1983 it covered only manufacturers and importers. OSHA expanded it to all industries in 1987. So auto shops, restaurants with cleaning chemicals, dental offices, janitorial services, construction crews, and hair salons are all potentially on the hook.

The exemptions are narrow. They include: ^[1]

• Hazardous waste operations covered under 29 CFR 1910.120 (those workers get HazCom training through that standard instead)
• Tobacco products, untreated wood, food and drink meant for employee consumption, drugs in sealed containers, and cosmetics in consumer quantities
• Consumer products used the same way, for the same duration, and at the same frequency a normal consumer would use them

That last one is tighter than people assume. A worker who uses a consumer cleaning spray the way a homeowner would is exempt. The same worker spraying it eight hours a day in a closed room is not.

Farm work covered by OSHA's field sanitation rules has some different provisions, and pesticide exposures fall partly under EPA. If you are in ag and unsure which rules apply, start with OSHA's agriculture section for sector guidance.

What are the penalties for violating the hazard communication standard?

OSHA penalties climb with inflation every year. As of 2024, a serious violation tops out at $16,550 per violation. Willful or repeated violations reach $165,514 per violation. ^[4]

A "serious" violation is one where OSHA finds a substantial probability that death or serious physical harm could result. Missing SDSs, unlabeled containers, untrained employees, all of those qualify. OSHA does not need to prove anyone got hurt. The potential for harm is enough.

HazCom citations stack. One inspection that turns up three unlabeled containers, a thin written program, and no training records can produce five or six separate citations. At $16,550 apiece, that adds up fast for a small shop.

The better news: OSHA discounts penalties for small employers. A business with 25 or fewer workers may get up to a 60% reduction; a business with 26 to 100 workers may get up to 40%. ^[4] Good-faith efforts to comply (even imperfect ones) and a clean history also count. A reduced penalty is still a penalty, though. Getting compliant before the inspection always costs less.

If an inspection happens and you disagree with a citation, you can contest it through OSHA's informal conference process or before the Occupational Safety and Health Review Commission. That process sits outside this article, but our incident report guide covers the documentation you want ready when OSHA shows up.

How does HazCom relate to the GHS and what changed in 2012?

Before 2012, the U.S. left a lot of classification and labeling calls to individual manufacturers. Two companies making the same chemical could classify it differently, format the MSDS differently, and use different labels. A worker moving between employers, or handling products from several suppliers, had to decode a new format every time.

OSHA's 2012 rewrite aligned HazCom with the sixth revised edition of the UN's Globally Harmonized System. ^[10] The GHS itself is not law anywhere. It is a framework that countries and regions adopt at their own pace, picking which parts to implement. The U.S. adopted it for worker hazard communication through 1910.1200; EPA adopted parts for pesticide labeling; DOT uses it for transport.

Four things changed in 2012: standardized hazard classification criteria, the 16-section SDS replacing the shapeless MSDS, standardized pictograms and signal words on labels, and a phased rollout that ran from 2013 to 2016. ^[11]

The full compliance deadline for all employers was June 1, 2016. After that, OSHA stopped accepting the old MSDS format. Still have old-format MSDSs in a binder somewhere? That is a citation risk. The content might be fine, but the format is wrong, and an inspector can write it up.

OSHA updated the standard again in May 2024 to align with the seventh and eighth revised editions of the GHS, with phased compliance dates running through 2027 and 2028. ^[5] The 2024 update changes some classification criteria, adds label requirements for small and fold-out containers, and revises some SDS content. If you built your program in 2016 and have not touched it since, now is the time to check it against the new rule.

What are employers' obligations when contractors or outside workers come into the facility?

This one causes real confusion. When contractors, temporary workers, or other outside employers send people into your facility, 29 CFR 1910.1200(e)(2) puts specific duties on you as the host employer. ^[1]

You have to tell the contractor's employer about any hazardous chemicals their workers may hit while on site, explain the precautions to take, describe the labeling systems you use, and make your SDSs available to their workers.

The contractor's employer trains their own people on the chemical hazards they bring in. A painting contractor who brings their own solvents trains their own crew. But if those solvents sit in a shared space where your workers might be exposed, you need to know about them and hold the SDSs.

The cleanest way to handle this is a pre-work meeting where you and the contractor swap chemical inventories and SDSs before work starts. Document it. It takes maybe 20 minutes and it closes a citation path OSHA is known to chase.

Temporary staffing is its own case. OSHA's guidance on temporary workers (issued through a series of directives starting in 2013) holds both the staffing agency and the host employer responsible for HazCom compliance. The host employer usually owns site-specific training, because the host is the one who knows which chemicals are on the floor. ^[6]

How do you handle trade secrets under the hazard communication standard?

Manufacturers can claim trade secret protection for the specific chemical identity of an ingredient under 29 CFR 1910.1200(i). ^[1] That does not let them hide the hazard. The SDS still has to disclose the health effects, physical hazards, and precautionary measures even when the actual chemical name is withheld.

Under the standard, "a statement that the specific chemical identity is being withheld as a trade secret" has to appear on the SDS where the chemical identity would normally sit. ^[1] Workers still get everything they need to protect themselves. They just do not get the exact name.

In a medical emergency, a treating physician or nurse can demand the specific chemical identity from the manufacturer, and the manufacturer has to hand it over immediately, even before a confidentiality agreement is signed. They can require the agreement to be signed as soon as circumstances allow, but they cannot stall during an acute emergency.

For you, the practical footprint is small. You are a downstream user passing along the SDS your supplier gave you. If that SDS claims a trade secret, you note it, train workers on the known hazards, and move on. Defending the trade secret claim is the supplier's job, not yours.

What records do you need to keep, and for how long?

The hazard communication standard sets no retention period for SDSs or training records. That does not mean you can toss them.

OSHA's Access to Employee Exposure Records standard (29 CFR 1910.1020) requires employers to keep employee exposure records, including SDSs for chemicals workers were exposed to, for 30 years after the worker's last exposure. ^[7] Thirty years. That length catches a lot of employers off guard.

The reasoning is medical. Latent effects from chemical exposure, like occupational cancer, can take decades to surface. If a worker develops a disease 25 years from now and tries to show they were exposed to a specific chemical at your facility, the SDS for that chemical is the document that matters.

So the practical rule: keep the SDS for any chemical in current use as long as you use it, plus 30 years after the last exposure. Retire a chemical and you archive its SDS instead of purging it. A dated archive file, even on paper, satisfies this as long as you can retrieve it.

Training records are not explicitly required by HazCom or 1910.1020, but keep them anyway. Inspectors ask for them, and without them you cannot prove training happened. Hold training records at least through employment plus a few years. Many safety pros keep them for the life of the business. Storage is cheap. Citations are not.

For the wider view of OSHA recordkeeping, including injury and illness logs, our guide to lockout tagout shows a parallel documentation structure worth studying.

How can a small business build a compliant HazCom program without hiring a consultant?

You do not need a consultant for this. Really. The standard is dense, but the steps to comply are not complicated once you break them apart.

Start with the chemical inventory. Walk every corner of the facility and write down every product that might be hazardous: cleaning supplies, lubricants, solvents, adhesives, paints, compressed gases, all of it. If the consumer version carries a warning label, assume it is covered. This list is the foundation for everything after it.

Next, pull SDSs for everything on the list. Suppliers are legally required to provide SDSs on request, and many post them online. OSHA's chemical database and the NIOSH Pocket Guide to Chemical Hazards make good cross-references. ^[8] A supplier who will not hand over an SDS is a red flag and a reason to shop elsewhere.

Then write the program. Take OSHA's sample program as a template and fill in your workplace, your inventory, and your training process. The sample lives on OSHA.gov. ^[1] Customization matters more than page count.

Now train your people. Walk them through the written program. Show them where the SDSs are. Pull a couple of real SDSs for chemicals they use often and explain what the sections mean. Then document it.

Last, check your labels. Every container should have a legible one. Worn or missing labels are an easy citation and an easy fix.

Want to skip the blank-page part? SafetyFolio's program generator builds a HazCom-compliant written program from your workplace inputs, so you get a document you can use instead of a generic template you have to reverse-engineer.

OSHA also runs a free on-site consultation program, separate from enforcement. A consultant visits, reviews your program, and tells you what to fix. It is confidential and does not trigger an inspection. ^[9] For small businesses it is genuinely useful, and it costs nothing.

Frequently asked questions

Does the hazard communication standard apply to small businesses with fewer than 10 employees?

Yes. There is no size exemption in 29 CFR 1910.1200. Any employer whose workers may be exposed to hazardous chemicals has to comply, regardless of headcount. The only break small businesses get is reduced penalties after a violation is found: employers with 25 or fewer workers may receive up to a 60% penalty reduction. The underlying requirements are identical for every size.

What is the difference between an SDS and the old MSDS?

The MSDS (Material Safety Data Sheet) was the pre-2012 format, with no required structure, so content and layout varied wildly between manufacturers. The SDS (Safety Data Sheet) replaced it under the 2012 GHS-aligned revision. Every SDS has exactly 16 sections in a set order. Old MSDS documents in the original format are no longer compliant; they had to be replaced by June 1, 2016.

What are the nine GHS pictograms and what do they mean?

The nine GHS pictograms are: flame (flammable), flame over circle (oxidizer), exploding bomb (explosive, self-reactive, organic peroxide), gas cylinder (gases under pressure), skull and crossbones (acute toxicity), corrosion (skin/eye corrosion, metal corrosive), health hazard (carcinogen, reproductive toxin, and other chronic hazards), exclamation mark (irritant, lesser acute toxin), and environment (aquatic hazard, not enforced by OSHA in the U.S.). Each sits inside a red diamond border.

How often does hazard communication training need to be repeated?

The standard requires training before initial assignment to work with hazardous chemicals and again whenever a new chemical hazard enters the work area. There is no mandatory annual refresher in the text of 29 CFR 1910.1200. In practice, many employers run annual refreshers because workplaces and products change, and because it is hard to prove you covered a newly introduced chemical otherwise. Refreshers also signal good faith to inspectors.

Can I store SDSs electronically instead of in a paper binder?

Yes. OSHA allows electronic SDS systems as long as workers can reach them during every shift without barriers. The computer or tablet has to sit in an accessible spot, workers must be trained to use it, and you need a backup plan (printed copies or a phone number) for when the system goes down. An SDS locked behind a password only management holds does not satisfy the standard.

What do I do if a chemical arrives without an SDS?

Do not let workers use the chemical until you have an SDS. Contact the supplier right away and request one in writing. Keep a record of the request. If the supplier goes quiet, contact the manufacturer directly. OSHA requires chemical manufacturers and importers to provide SDSs with the initial shipment and with the first shipment after an SDS is updated. Receiving a chemical without one is the supplier's violation, but protecting your workers is still your job.

Does the hazard communication standard cover gases as well as liquids and solids?

Yes. The standard covers chemicals in any physical state: solids, liquids, and gases. Compressed gases and gases under pressure have their own GHS hazard categories and require the gas cylinder pictogram on labels and SDSs. Common examples include acetylene, oxygen, carbon dioxide, and nitrogen. Employers who use compressed gas cylinders need an SDS for each gas and have to keep cylinders labeled.

What is the hazard communication standard poster and do I have to post it?

There is no specific mandatory HazCom poster. The required posting is OSHA's general 'Job Safety and Health: It's the Law' poster (OSHA 3165), which has to be displayed in every workplace OSHA covers. Many employers also post a supplemental HazCom notice explaining where SDSs are kept and how to access them. Those notices are good practice, not an independent requirement under 29 CFR 1910.1200.

How does the 2024 update to the hazard communication standard change what I have to do?

OSHA's May 2024 revision aligns HazCom with the seventh and eighth revised editions of the GHS. Key changes include revised classification criteria for some categories, new requirements for small container labels (fold-out labels or other alternatives when a container is too small for a full label), and additional SDS content. Compliance deadlines run through 2027 and 2028 depending on whether you are a manufacturer, importer, or downstream employer.

Are household cleaning products used at work covered by HazCom?

It depends on how they are used. OSHA's consumer product exemption covers products used the same way, for the same duration, and at the same frequency a normal consumer would use them. A spray bottle of multi-surface cleaner used now and then in a break room probably qualifies. The same product used by a janitor all day in a closed space does not. When in doubt, get the SDS and treat it as covered.

What records does OSHA inspect during a hazard communication audit?

A compliance officer will usually ask for your written HazCom program, your complete chemical inventory, SDSs for chemicals in the workplace, and proof of employee training. They will also walk the floor to check container labels and SDS access. No written program is a citable violation on its own. Outdated, inaccessible, or incomplete SDSs are separate violations. Training with no documentation is hard to defend.

Do temporary or staffing agency workers need HazCom training?

Yes, and the staffing agency and host employer share the responsibility. OSHA's guidance since 2013 holds host employers responsible for site-specific HazCom training because they know which chemicals are present. The staffing agency handles general HazCom training. The host employer has to provide chemical-specific training before temporary workers are exposed and has to document it just like it would for direct employees.

Can employers be fined for not having a written hazard communication program even if they have SDSs and labels?

Yes. The written program is a separate, independently citable requirement under 29 CFR 1910.1200(e). Having SDSs and labels in place does not cover it. Inspectors regularly cite missing or thin written programs as a standalone violation even when the rest of your HazCom setup is in order. The written program is also the framework OSHA uses to judge whether your overall system holds together.

How does hazard communication interact with OSHA's PPE standard?

Section 8 of every SDS lists exposure limits (OSHA PELs, ACGIH TLVs) and required PPE for the chemical. That feeds straight into your PPE program under 29 CFR 1910.132, which requires a workplace hazard assessment to figure out what PPE you need. The two standards work together: the SDS tells you what protection is needed, and the PPE standard governs how you select, provide, and train workers on it.

Sources

1. OSHA, Hazard Communication Standard, 29 CFR 1910.1200: Full requirements of the HazCom standard including written program, SDS, labeling, and training obligations
2. OSHA, Top 10 Most Frequently Cited Standards FY2023: Hazard Communication was the second most-cited OSHA standard in FY2023 with more than 3,200 violations
3. OSHA, Job Safety and Health Poster (OSHA 3165): OSHA's general Job Safety and Health poster is required to be posted in every covered workplace
4. OSHA, Penalties page: Maximum penalty for a serious violation is $16,550 per violation as of 2024; willful or repeated violations up to $165,514; small employers may receive penalty reductions
5. OSHA, Hazard Communication Standard 2024 Final Rule: OSHA published a 2024 update to HazCom aligning with GHS 7th and 8th revised editions, with compliance dates through 2027 and 2028
6. OSHA, Protecting Temporary Workers guidance: Both host employers and staffing agencies share responsibility for HazCom compliance for temporary workers; host employers responsible for site-specific training
7. OSHA, Access to Employee Exposure and Medical Records, 29 CFR 1910.1020: Employee exposure records including SDSs must be retained for 30 years after the employee's last exposure
8. NIOSH, Pocket Guide to Chemical Hazards: NIOSH Pocket Guide is a useful reference for chemical hazard information and exposure limits
9. OSHA, On-Site Consultation Program: OSHA's free on-site consultation program is confidential, separate from enforcement, and available to small businesses
10. OSHA, GHS Implementation in the United States: OSHA's 2012 revision aligned HazCom with the sixth revised edition of the UN GHS; the GHS is a framework that countries adopt individually
11. OSHA, Hazard Communication Standard Final Rule, Federal Register Vol. 77 No. 58, 2012: The 2012 revision standardized SDS to 16 sections, established GHS pictograms and signal words, and set phased implementation deadlines with full compliance required by June 1, 2016