A hazard communication program requires which of the following components

Last updated 2026-07-09

What does OSHA's Hazard Communication Standard actually require?

The Hazard Communication Standard lives at 29 CFR 1910.1200, and OSHA enforces it harder than almost anything else in its book. In fiscal year 2023, HazCom ranked second on OSHA's top-ten most-cited list, with 3,213 federal citations ^[1]. That number has barely moved in a decade. The standard applies to any employer where workers may be exposed to hazardous chemicals, which covers most manufacturing, construction, agriculture, and service workplaces.

People call it the "Right-to-Know" rule. Others call it "GHS," short for the Globally Harmonized System of Classification and Labeling of Chemicals. OSHA aligned the standard with GHS in 2012, which brought in the current 16-section Safety Data Sheet format and rewrote the labeling rules ^[2]. If your program was written before 2013 and nobody has touched it since, it almost certainly has gaps.

Here's the skeleton. Paragraph (e) of 1910.1200 describes the written program. Paragraph (g) covers labels. Paragraph (h) covers Safety Data Sheets. Paragraph (i) covers training. Read those four paragraphs and you understand the shape of the whole thing. The sections below fill in what each one actually demands.

What are the six required components of a hazard communication program?

OSHA's standard breaks into six parts, and every employer needs all six. A compliance officer who walks your facility will check for each one. Here they are in plain language.

1. A written hazard communication program. This is the document that ties everything together. It has to describe how your workplace meets each requirement: how you handle labels, where SDSs live, how you run training, and how you cover non-routine tasks and outside contractors. Plenty of employers write a generic statement and figure they're done. That fails. The program has to be specific to your workplace and name the actual methods and locations you use ^[3].

2. A chemical inventory list. You must compile and keep a list of every hazardous chemical in your workplace. Under 1910.1200(c), a "hazardous chemical" is any chemical that is a physical or health hazard, a simple asphyxiant, a combustible dust, a pyrophoric gas, or a hazard to the ozone layer. The inventory is the foundation for everything else. You can't train people on chemicals you never identified, and you can't keep SDSs for chemicals you don't know you have ^[3].

3. Safety Data Sheets (SDSs) for every hazardous chemical. You need a current SDS for each hazardous chemical on the inventory, and workers have to reach them during their shift without asking a supervisor for a key or a password. The standard at 1910.1200(g)(8) requires "immediate access." Electronic systems are fine, but only if you have a reliable backup for power or equipment failures ^[4].

4. Labels on all containers. Every container of hazardous chemical has to be labeled. The label needs the product identifier, a signal word (Danger or Warning), hazard statements, pictograms, precautionary statements, and the name and contact information of the manufacturer or importer. Pour a chemical into a smaller container for one worker to use up during one shift and you get a narrow exemption. Every other portable container needs a label ^[2].

5. Employee training. Training happens before a worker's first assignment to an area with hazardous chemicals, and again whenever a new hazard shows up. It has to cover the HazCom standard itself, where the written program and SDSs are, how to read labels and SDSs, and the specific hazards of the chemicals in that worker's area. A generic online video that never mentions your chemicals or your workplace does not clear the bar ^[3].

6. A system for non-routine tasks and contractor employers. When workers do a task outside their normal routine (cleaning out a storage tank, say), you have to tell them the chemical hazards they'll hit and the protective measures required. You also have to give contractor employers access to your SDSs, tell them about precautions for the chemicals in the area where they'll work, and explain any labeling system you use. This is the component most employers forget ^[3].

What exactly must a written hazard communication program contain?

The written program is the spine of the whole system. 29 CFR 1910.1200(e)(1) says it must describe how the criteria for labels, SDSs, and training get met in your workplace. It also has to include the list of hazardous chemicals and the methods you use to inform employees about the hazards of non-routine tasks.

In practice, compliance officers expect to see these elements spelled out: who is responsible for each part of the program, where the chemical inventory lives and who updates it, where SDSs are stored and how employees reach them on every shift, the training schedule and format, and the procedure for talking to contractor employers. "SDSs are available upon request" is not a program. It's a dodge, and OSHA treats it that way ^[3].

The program has to be available to employees and their designated representatives at all times. OSHA allows an electronic format, but workers need to reach it without jumping through hoops.

One point worth pinning down: the standard says "shall" throughout, not "should." These are mandatory, not suggestions. If a compliance officer finds a written program that describes a system your workplace doesn't actually run, you can get cited twice: once for the program deficiency and once for the underlying violation the paper was supposed to prevent.

What must Safety Data Sheets include under the GHS format?

Since OSHA's 2012 update, every SDS follows the same 16-section layout. The standard at 1910.1200(g) and Appendix D spells out each section ^[4]. Here's what they cover:

Section	Title	What it contains
1	Identification	Product name, manufacturer contact, recommended uses
2	Hazard(s) identification	GHS classification, signal word, hazard and precautionary statements
3	Composition/ingredients	Chemical identity, CAS numbers, trade secret provisions
4	First-aid measures	Symptoms and required treatment by exposure route
5	Fire-fighting measures	Suitable extinguishing media, specific hazards from combustion
6	Accidental release measures	Spill procedures, PPE for cleanup, disposal
7	Handling and storage	Safe handling precautions, storage conditions
8	Exposure controls/PPE	OSHA PELs, ACGIH TLVs, required PPE
9	Physical and chemical properties	Appearance, odor, pH, flash point, etc.
10	Stability and reactivity	Conditions to avoid, incompatible materials
11	Toxicological information	Routes of exposure, acute and chronic effects
12	Ecological information	Not enforced by OSHA, but required by EPA under TSCA
13	Disposal considerations	Not enforced by OSHA
14	Transport information	Not enforced by OSHA
15	Regulatory information	OSHA, EPA, state regulations
16	Other information	Date of preparation or last revision

Sections 12 through 15 are required by GHS but sit outside OSHA's jurisdiction. A complete SDS from a reputable manufacturer will still include them.

You don't write SDSs for chemicals you buy. You get them from the manufacturer or importer. Your job is to obtain them, keep them current, and make them reachable. If a supplier can't or won't provide an SDS for a hazardous chemical, you have to track one down from another source before your workers touch that chemical ^[4].

What do container labels have to say?

Labels are the warning at the point of use, and the 2012 GHS update made the requirements sharper than they'd ever been. Under 1910.1200(f), every container has to show six things: the product identifier, a signal word, hazard statements, precautionary statements, pictograms, and the name, address, and phone number of the manufacturer, importer, or other responsible party ^[2].

The signal word is either "Danger" for more severe hazards or "Warning" for less severe ones. You never see both on the same label. The pictograms are the GHS red-bordered diamonds: flame, skull and crossbones, corrosion, exclamation mark, health hazard, gas cylinder, environment, and exploding bomb. Nine total. A single label can carry several.

For workplace containers, 1910.1200(f)(6) lets employers use any labeling system, including workplace tags or color codes, as long as employees are trained on it and it conveys hazard information at least as well as a GHS label. NFPA 704 diamond placards and HMIS labels are common stand-ins. Whatever you use, your written program has to describe it and your training has to cover it.

One thing trips up a lot of small shops: pipes. OSHA does not make you slap a full GHS label on every run of pipe. But workers need some way to know what's inside. A color code, tags, or process sheets posted at the point of use all work, as long as they're in your written program and covered in training.

What does HazCom training actually have to cover?

Training is required before a worker's first assignment and again whenever a new physical or health hazard shows up. OSHA specifies at 1910.1200(h) that training must cover the methods workers use to detect the presence or release of hazardous chemicals, the physical and health hazards (plus simple asphyxiation, combustible dust, and pyrophoric gas hazards), the measures workers can take to protect themselves, and the details of the written program including how to reach SDSs and read labels ^[3].

Training has to match the employee's actual work area. A worker who only runs the paint room doesn't need a deep session on the acids over in plating, but they do need complete training on every hazardous chemical they might touch in their own space. A lot of employers skip that specificity, and it's exactly why training citations pile up.

OSHA doesn't set a required format or length. In-person, video, online, written, or a mix all work, as long as the content hits the required points and workers actually understand it. If some of your workers don't read English well, training has to happen in a language they understand. OSHA has confirmed this in letters of interpretation more than once ^[5].

Documentation isn't spelled out in 1910.1200, but writing down who got trained, on what date, and which chemicals you covered is the only way to defend yourself during an inspection or after an incident. Keep the records. If you're building this from scratch, our workplace safety training guide can help you structure the content and the recordkeeping.

For how HazCom fits inside a full safety system, our overview of hazardous communication is a useful supplement to the standard itself.

How do you handle non-routine tasks and contractor employers?

This is the piece that surprises employers during inspections. Non-routine tasks are jobs that happen rarely or outside normal operations: cleaning an equipment tank, applying a specialized coating, doing maintenance in a normally-restricted area. Paragraph 1910.1200(e)(1)(i) requires the written program to describe how you inform employees about chemical hazards from those tasks.

Before you assign someone to a non-routine task, identify the hazardous chemicals involved, pull or provide the relevant SDSs, and brief the worker on the specific hazards, the PPE, and the emergency procedures. A verbal heads-up on the way out the door is not enough unless it sits on top of a systematic process your written program describes.

For contractors, 1910.1200(e)(2) requires a two-way exchange. You inform contractor employers of any hazardous chemicals they might hit in your facility, give them access to the SDSs, and explain any labeling system you use. In return, contractor employers tell their own workers about the chemicals they bring in. So you want a written contractor check-in procedure that includes a HazCom briefing, something more than a badge and a visitor log.

This is the section most citations ignore, and it's the one that gets people hurt. A contractor's worker who doesn't know about a chemical hazard in your building and gets injured leaves both employers staring down OSHA liability.

Which industries and employers does HazCom apply to?

The Hazard Communication Standard applies to nearly every employer, with only narrow carve-outs. The original 1983 rule covered manufacturing. OSHA expanded it to all industries in 1987 ^[2]. Today, general industry uses 29 CFR 1910.1200, construction uses 29 CFR 1926.59 (which just pulls in 1910.1200 by reference), maritime uses 29 CFR 1915.99, and agriculture uses 29 CFR 1928.21 ^[6].

State plan states run their own OSHA programs and must have HazCom standards at least as effective as the federal one. California is the clearest example: Cal/OSHA enforces Title 8, CCR Section 5194, which is substantively identical to the federal rule ^[7]. If you're in a state plan state, follow your state's version, not the federal text.

Small employers get no pass. There is no size threshold. A one-person shop that keeps a can of spray lubricant needs a written program, an SDS for that lubricant, a label on every container, and documented training for that single worker. The program can scale to the size of your chemical inventory. It just has to exist ^[10].

What are the most common HazCom violations OSHA cites?

OSHA's top-cited HazCom problems cluster in four spots. First, missing or incomplete SDSs: employers either don't have them for everything on-site, or they're sitting on outdated pre-GHS Material Safety Data Sheets that don't meet the 16-section format. Second, bad labels on secondary containers. Workers pour chemicals into unlabeled spray bottles all day, and that's a citation waiting to happen. Third, written programs that are generic templates with zero site-specific detail. Downloading a boilerplate form and filing it away does not satisfy anything ^[1].

Fourth, and probably the most cited sub-element, is weak employee training. Inspectors ask workers directly. What chemical hazards do you work with? Can you read a Safety Data Sheet? Where are they kept? If the answers come back blank, the employer gets cited even when training records show people signed in for a class.

Penalties depend on classification. In 2024, OSHA's maximum for a serious violation is $16,550, and willful or repeat violations can reach $165,514 each ^[8]. One inspection can produce several violations if several parts of your program are broken.

If you're starting fresh or auditing what you have, SafetyFolio's safety program generator can produce a site-specific written HazCom program in about 15 minutes. Treat that as a starting point, then layer in your real chemical inventory and area-specific training.

How does OSHA's GHS update change what was required before 2012?

Before 2012, the standard called for Material Safety Data Sheets (MSDSs) in a loose format, and labels just had to convey hazard information without any set structure. Manufacturers used whatever layout they liked, which made it hard for workers to find the same information twice.

The 2012 update, phased in through June 2016, changed four things. Manufacturers had to classify hazards using specific GHS criteria and assign GHS categories. SDSs shifted to the fixed 16-section format. Labels got standardized elements: signal words, pictograms, hazard statements, and precautionary statements. And employers had to train workers on the new label elements and SDS format by December 1, 2013 ^[2].

If your supplier is still handing you pre-GHS MSDSs, that's a warning about the supplier, not a defense for you. Your obligation is to hold compliant SDSs. Go pull them from the manufacturer's website or call the company. The standard at 1910.1200(g)(6) says you can develop an SDS yourself if a supplier fails to provide one, though in real life most employers would just find a different supplier.

For how a full safety and health program should be built around HazCom and other standards, see our guide on what a safety and health program should be, and OSHA's free Recommended Practices for Safety and Health Programs ^[11] puts HazCom in the bigger picture.

How do you build and document a HazCom program that will survive an inspection?

Start with the chemical inventory. Walk the facility with a clipboard and find every chemical product on-site, including the maintenance closet, the breakroom (cleaning products count), and the vehicles. Note the product name and manufacturer, then flag whether an SDS exists and whether it's in the current 16-section format. That list is your foundation.

For each chemical, get or confirm a current GHS-compliant SDS. Most manufacturers post them online. Build a master binder or an electronic folder organized by chemical name or SDS number, decide where it lives, and pick who maintains it. Write that location and that person's name into the program.

Draft the written program to match what you actually do, not what reads well. If SDSs sit in a binder in the supervisor's office and night-shift workers reach them by calling the supervisor, write that down. Then ask the hard question: is that "immediate access" under 1910.1200(g)(8)? If it isn't, fix the process first, then document the fixed version.

For training, run it in person or with a video supplement, but build in a hands-on piece where workers actually find and read an SDS for a chemical in their area, read a label, and name the pictograms. Keep a sign-in sheet with the date, topic, chemicals covered, and trainer's name. Scan it. Keep it indefinitely.

For contractors, make a one-page chemical hazard briefing form that gets filled out at check-in. Have the contractor sign it. Give them a copy and file yours.

Review the whole thing at least once a year and any time you add chemicals, change a process, or hire. Most programs that fail inspections aren't wrong. They're just stale.

Frequently asked questions

Is a written hazard communication program required even if we only use a few chemicals?

Yes. 29 CFR 1910.1200 has no minimum chemical threshold. If any hazardous chemical is present, you need a written program, an inventory, SDSs, labels, and training. The program can be short if your inventory is small, but it has to exist and be specific to your workplace. A generic template you never customized does not meet the requirement.

Can employees access Safety Data Sheets electronically, or do we need paper copies?

Electronic access is allowed under 1910.1200(g)(8), but only if workers reach SDSs immediately during their shift without barriers and you have a reliable backup for when computers or the network go down. OSHA has accepted kiosks, shared terminals, and tablets. The backup requirement is real. You need a plan for outages and system failures, usually a paper binder for the common chemicals.

What chemicals are covered under OSHA's Hazard Communication Standard?

Any chemical that is a physical hazard (flammable, explosive, oxidizer, and so on) or a health hazard (toxic, carcinogen, irritant), plus simple asphyxiants, combustible dusts, pyrophoric gases, and chemicals hazardous to the ozone layer. Consumer products used the same way and at the same frequency a normal consumer would use them are generally exempt. Wood and wood products not processed further are also exempt under 1910.1200(b)(6).

How often does HazCom training need to be repeated?

OSHA requires training before initial assignment and whenever a new physical or health hazard is introduced. There is no explicit annual retraining requirement in 1910.1200. But if you add a chemical, change a process, or an incident shows workers don't understand hazard information, you train again. Many employers run annual refreshers anyway, both as good practice and to defend against a worker claiming they were never trained.

What is the difference between an MSDS and an SDS?

Material Safety Data Sheets (MSDSs) were the pre-2012 format with no fixed structure. Safety Data Sheets (SDSs) are the current GHS-aligned format with the mandatory 16-section layout in 1910.1200 Appendix D. OSHA's transition deadline for the new format was June 1, 2016. If a supplier still hands you an MSDS instead of a GHS-compliant SDS, that sheet is not compliant, and you should contact the manufacturer for a current one.

Do labels on shipped containers need to be replaced with GHS labels once they arrive?

No. Manufacturers and importers are responsible for GHS-compliant labels on shipped containers. As the end user, you must not remove or deface an existing label. Your obligation kicks in for workplace containers you fill yourself, like secondary containers and process vessels. Those need labels under whatever system you describe in your written program, whether that's a GHS label, a workplace tag, or a color code.

What happens if a contractor brings hazardous chemicals into our facility?

Under 1910.1200(e)(2), the contractor employer must provide SDSs for any chemicals they bring in, make them available to your workers who might be exposed, and tell you about any labeling systems or precautions required. Your written program should include a contractor onboarding procedure that covers this exchange. You inform contractor workers of hazards already in your facility, and they handle the hazards they introduce.

Can we use NFPA 704 diamonds or HMIS labels instead of GHS labels on containers?

Yes, for workplace containers. 1910.1200(f)(6) allows alternative labeling systems, including NFPA and HMIS, as long as the system conveys hazard information at least as well as GHS labels and workers are trained on it. The alternative has to be described in your written program. Shipped containers from manufacturers still carry GHS labels. You can't swap NFPA or HMIS onto those.

Are there HazCom requirements specific to construction workers?

Construction employers follow 29 CFR 1926.59, which pulls in the general industry standard at 1910.1200 by reference. The substantive requirements are identical. Construction sites are tricky because multiple contractors share the same space, each with their own chemicals. The multi-employer and contractor communication provisions of 1910.1200(e)(2) are especially relevant and often cited on job sites.

What are the OSHA penalties for HazCom violations?

In 2024, OSHA's maximum penalty for a serious HazCom violation is $16,550 per violation. Willful or repeat violations can reach $165,514 per violation. One inspection can generate several violations if multiple parts of your program are deficient. Employers with 10 or fewer workers in low-hazard industries may qualify for reduced penalties, but the violations themselves are still citable regardless of size.

Does HazCom apply to state plan states the same way it does to federal OSHA states?

State plan states must have HazCom standards at least as effective as the federal one, and most adopt rules that mirror 1910.1200 closely. California's Cal/OSHA enforces Title 8, Section 5194, substantively identical to the federal rule. If your state runs its own OSHA program, check your state agency's website for extras. The 28 state plan jurisdictions include California, Michigan, Washington, and North Carolina ^[12].

How do we handle hazardous chemicals in pipes and process equipment?

OSHA does not require GHS labels on every section of pipe or piece of process equipment. But workers must have some way to know what hazardous chemicals are in the pipes they work on or near. Acceptable methods include color-coded piping, posted process flow diagrams, tags at access points, or written procedures handed out before each task. Whatever method you pick has to be in your written program and covered in training.

What records do we need to keep for HazCom compliance?

The standard doesn't list specific recordkeeping beyond maintaining the written program, chemical inventory, and SDSs. Training records aren't explicitly mandated, but compliance officers will ask for proof training happened. Keeping sign-in sheets with dates, chemicals covered, and trainer names is strongly advisable. SDS revision dates matter too. If a chemical's hazard profile changes, you need the updated SDS and may need to retrain.

Does HazCom cover pesticides and agricultural chemicals?

Agricultural operations follow 29 CFR 1928.21, which applies selected general industry standards to agriculture. Pesticides regulated under FIFRA (the Federal Insecticide, Fungicide, and Rodenticide Act) carry separate EPA labeling that OSHA accepts as an alternative label for shipped containers. Agricultural employers using pesticides still need SDSs and training under the applicable standard. Check with your state agriculture department for any state-level requirements.

Sources

1. OSHA, Top 10 Most Cited Standards FY2023: HazCom (29 CFR 1910.1200) ranked second on OSHA's most-cited list in FY2023 with 3,213 federal citations
2. OSHA, Hazard Communication (GHS alignment overview): OSHA updated the Hazard Communication Standard in 2012 to align with GHS, requiring 16-section SDS format and revised labeling elements; compliance deadline for new labels and SDSs was June 1, 2016
3. OSHA, 29 CFR 1910.1200 Hazard Communication Standard full text: Paragraphs (e), (h), (i) of 1910.1200 specify the written program, training, and non-routine task/contractor requirements
4. OSHA, 29 CFR 1910.1200 Appendix D, Safety Data Sheets format requirements: Appendix D specifies all 16 required sections of a GHS-compliant Safety Data Sheet; employees must have immediate access to SDSs per 1910.1200(g)(8)
5. OSHA, Letters of Interpretation (Hazard Communication): OSHA interpretation letters confirm HazCom training must be provided in a language and vocabulary workers can understand
6. OSHA, 29 CFR 1926.59 Construction Hazard Communication: 29 CFR 1926.59 applies HazCom requirements to construction employers by incorporating 1910.1200 by reference
7. California Department of Industrial Relations, Cal/OSHA: Cal/OSHA enforces Title 8, CCR Section 5194, a HazCom regulation substantively identical to the federal standard
8. OSHA, Penalties, 2024 penalty amounts: In 2024, OSHA's maximum penalty for a serious violation is $16,550; willful or repeat violations can reach $165,514 per violation
9. OSHA, Small Entity Compliance Guide for the Revised Hazard Communication Standard (OSHA Publication 3695): OSHA guidance confirms that all employers regardless of size must comply with 1910.1200 if hazardous chemicals are present, with no minimum employee or chemical threshold
10. OSHA, Recommended Practices for Safety and Health Programs: OSHA's recommended practices guide places HazCom within a broader safety and health management system framework
11. OSHA, State Plans page listing state plan states: 28 states and territories operate OSHA-approved state plans and must maintain HazCom standards at least as effective as the federal rule