GHS hazard communication: what every employer must know

Last updated 2026-07-09

What is GHS hazard communication and why does OSHA require it?

GHS stands for the Globally Harmonized System of Classification and Labelling of Chemicals. It's a United Nations framework, first published in 2003, that gives every country a shared language for describing chemical hazards. OSHA folded GHS into the federal Hazard Communication Standard in 2012, rewriting 29 CFR 1910.1200 so U.S. labels and Safety Data Sheets would match the format used in Canada, the EU, Japan, and dozens of other countries. ^[1][11]

Before 2012, OSHA's HazCom standard told employers to communicate hazards but left the format mostly up to them. Material Safety Data Sheets came in wildly different layouts. Labels could look like anything. GHS fixed that by standardizing five label elements (pictograms, signal words, hazard statements, precautionary statements, and product identifier), a single 16-section SDS format, and the classification criteria for physical and health hazards.

The reason behind the rule is blunt. Workers who don't know what's in the drum next to them can't protect themselves. OSHA estimates that roughly 32 million workers are exposed to about 650,000 hazardous chemical products on the job. ^[2] Chemical exposure causes or contributes to thousands of occupational illnesses a year, and ignorance is the most preventable risk factor in that count.

General industry follows 29 CFR 1910.1200. Construction gets it at 29 CFR 1926.59, maritime at 29 CFR 1915.99, and agriculture at 29 CFR 1928.21, but all three point back to 1910.1200 by reference. If you work in any of those sectors, the same core requirements land on you.

Who does the hazard communication standard apply to?

Almost everyone. The standard covers any employer whose workers may be exposed to hazardous chemicals under normal conditions of use or in a foreseeable emergency. ^[1] That language reaches further than most small business owners expect.

You're covered if you run a commercial kitchen that uses oven cleaner. You're covered if your office stocks copier toner. You're covered if your auto shop keeps brake fluid and carburetor cleaner on a shelf. OSHA does carve out a few narrow exemptions: consumer products used the same way and at the same frequency a regular consumer would use them, foods regulated by FDA, drugs meant for personal consumption, and a handful of other tight categories. ^[1] Push past normal consumer quantities or durations, and the exemption disappears.

Retailers sometimes assume they're off the hook because they don't "make" chemicals. Wrong. The rule covers use and storage, more than manufacturing. A janitorial supply company whose crew stocks shelves of bleach and ammonia needs a HazCom program every bit as much as a chemical plant does.

Downstream employers (everyone who isn't the chemical maker) carry the lightest load. You don't classify chemicals yourself. Manufacturers and importers do that and hand you compliant labels and SDSs. Your job is to use those labels right, keep the SDSs, write a program, and train your people. That's the whole deal, stripped down.

What are the five core requirements of the GHS HazCom standard?

OSHA's 29 CFR 1910.1200 comes down to five duties for most employers. Here they are in plain terms.

1. Written hazard communication program. You need a written program that spells out how your workplace meets each part of the standard. It has to include a list of every hazardous chemical on site, explain how you handle labels and SDSs, and describe your training. ^[1] It has to fit your workplace, not sit as a generic form with your company name pasted on top. OSHA has cited exactly that kind of boilerplate document as noncompliant during inspections.

2. Chemical inventory list. The written program has to include, or point to, a list of every hazardous chemical in the workplace, using the product name from the SDS. This is your chemical inventory. A spreadsheet works fine. It just has to exist and stay current.

3. Labels on containers. Every container of a hazardous chemical needs a label. For containers from a supplier, you use the supplier's label. For containers you fill or transfer into yourself, you label them using the GHS elements: pictogram(s), signal word, hazard statements, precautionary statements, product identifier, and supplier information. ^[1] Our guide to hazard communication labels breaks down what each element requires.

4. Safety Data Sheets (SDSs). You must keep an SDS for every hazardous chemical you use and make them reachable during every shift. ^[1] "Accessible" means a worker can get to the SDS without asking a manager and without leaving the work area in a way that would put them in harm's way. Electronic systems pass, as long as you have a reliable backup for when the network drops.

5. Training. Workers get trained before their first assignment near hazardous chemicals, and again whenever a new chemical hazard shows up in their work area. ^[1] The content is more specific than most employers guess. The training section below covers it.

What do GHS labels actually have to include?

A compliant GHS label carries six required elements under 29 CFR 1910.1200(f). Miss one and the label fails.

Product identifier. The name or number that matches the SDS. It can be a chemical name, trade name, or code, as long as the SDS uses the same one.

Signal word. Either "Danger" (more severe hazard) or "Warning" (less severe). Only one signal word appears on a label, even when a product carries several hazards.

Hazard statements. Standard phrases describing the hazard, like "Causes serious eye damage" or "May cause cancer."

Precautionary statements. Instructions for safe handling, storage, disposal, and first aid. These are also fixed phrases pulled from the GHS system.

Pictogram(s). The nine GHS pictograms are diamond-shaped with a red border and a black symbol inside. Each covers a hazard category: flame, skull and crossbones, corrosion, exclamation mark, health hazard, environment, exploding bomb, oxidizer, and compressed gas. ^[4]

Supplier information. The name, address, and phone number of the manufacturer, importer, or responsible party.

For workplace (secondary) containers, the rules loosen. You can use a simplified label with at least the product identifier and hazard information, or a system like NFPA 704 diamonds or HMIS labels, as long as workers are trained to read them. ^[1] Everything rides on "trained to read them." An alternative system only works if people actually know what the numbers and colors mean.

What are Safety Data Sheets and what do the 16 sections cover?

Safety Data Sheets replaced Material Safety Data Sheets when OSHA adopted GHS in 2012. The name changed, and so did the layout. Every SDS follows the same 16-section structure. ^[1]

Section	Content
1	Identification (product name, supplier, recommended use)
2	Hazard identification (GHS classification, label elements)
3	Composition / information on ingredients
4	First-aid measures
5	Fire-fighting measures
6	Accidental release measures (spill response)
7	Handling and storage
8	Exposure controls / personal protective equipment
9	Physical and chemical properties
10	Stability and reactivity
11	Toxicological information
12	Ecological information
13	Disposal considerations
14	Transport information
15	Regulatory information
16	Other information (including SDS revision date)

Sections 1 through 11 are the ones OSHA enforces. Sections 12 through 15 answer to other agencies (EPA, DOT) and still have to appear on the sheet even though OSHA doesn't enforce them on its own. Section 16 is a catch-all.

You don't write SDSs. Your supplier does. You're on the hook for getting them, keeping them current, and keeping them reachable. If a supplier can't or won't hand over an SDS for something you're buying, treat that as a warning sign. OSHA's guidance is to contact the manufacturer directly. ^[3] If the sheet still never arrives, stop using the product until it does.

Plenty of employers now run SDSs through management software or a shared drive. Whatever you use, write down a backup plan for when the network is down, because workers need access during outages, emergencies, and every ordinary shift in between.

What does GHS hazard communication training have to cover?

Training is where a lot of small businesses fall short. The rule at 29 CFR 1910.1200(h) lays out exactly what training must include, more than that it must happen. ^[1]

Your hazard communication training program has to cover:

• The requirements of the HazCom standard itself, so workers understand their rights under the rule.
• The location and availability of the written program, the chemical inventory, and the SDSs.
• How to detect the presence or release of a hazardous chemical, including visual signs, smell, or monitoring instruments.
• Physical and health hazards of the chemicals in the work area, including the signs and symptoms of exposure.
• Protective measures workers can take: engineering controls, work practices, and PPE.
• How to read and use a GHS label, including what each pictogram means.
• How to find and use an SDS.

OSHA sets no minimum hours and issues no certification card for HazCom training, unlike forklift certification training. What the standard demands is training that's "effective," meaning workers can show they understand the hazards in their area and how to protect themselves. ^[1]

Who needs hazard communication training? Any employee who may be exposed during normal work or a foreseeable emergency. That takes in part-time, seasonal, and temporary workers. Training happens before the first exposure, so if chemicals are present on day one, orientation week is too late. ^[1]

Language matters here too. If your workers read Spanish and not English, a class taught only in English doesn't meet the "effective" bar. You train in a language and at a reading level your people actually follow. OSHA has said this in more than one letter of interpretation. ^[3]

For a closer look at what effective training looks like and how to document it, see our guide to hazardous communication training.

What does a compliant written hazard communication program look like?

The written program is the spine of your HazCom compliance. Under 29 CFR 1910.1200(e), it has to, at minimum: ^[1]

• Describe how you meet the labeling requirements, including how you handle workplace (secondary) containers.
• Describe how you obtain and maintain SDSs.
• Describe the training you provide and when.
• Include or reference the chemical inventory list.
• Explain how you inform other employers about hazards when contractors work in your facility.

That last point trips up a lot of small businesses. If a painting contractor shows up to repaint your warehouse, you have to warn them about any chemical hazards they might hit in that space, and they have to warn you about the paints and solvents they're bringing in. OSHA calls this multi-employer coordination, and it lives at 1910.1200(e)(2). ^[1]

The program has to fit your workplace. You can start from a template, and a tool like SafetyFolio's safety program generator can build a HazCom program tailored to your industry and chemicals in about 15 minutes instead of half a day. But whatever you start from, adapt it: name your actual chemicals, describe where SDSs really sit in your building, and describe the training your people really get. Generic programs fail inspections. Specific, accurate ones pass.

OSHA has to be able to review your program during an inspection. Keep it at the worksite. Keep it current. Update it every time you add a chemical or change a process.

What are the GHS pictograms and what do they mean?

There are nine GHS pictograms. Each is a diamond with a red border and a black symbol on a white background. Reading them is basic literacy for anyone working around chemicals, so it's worth laying out plainly.

Pictogram symbol	Hazard category
Flame	Flammable liquids, gases, solids; self-reactives; pyrophorics; self-heating; emits flammable gas
Flame over circle	Oxidizers
Exploding bomb	Explosives; self-reactives; organic peroxides
Skull and crossbones	Acute toxicity (fatal or toxic)
Corrosion	Skin corrosion; serious eye damage; corrosive to metals
Exclamation mark	Skin/eye irritation; skin sensitization; harmful if swallowed/inhaled; specific target organ toxicity (single, narcotic effects); hazardous to ozone layer
Health hazard (human silhouette)	Carcinogen; reproductive toxicity; respiratory sensitizer; target organ toxicity; aspiration hazard; mutagenicity
Gas cylinder	Gases under pressure
Environment (tree and fish)	Aquatic toxicity (not OSHA-enforced, but present on SDSs)

A product can carry several pictograms if it falls into several hazard categories. The environment pictogram answers to other regulations, but OSHA doesn't enforce it on its own under 1910.1200, so don't be thrown if a label shows it or leaves it off. ^[1]

For the visual reference straight from the source, OSHA's Hazard Communication pictogram page covers all nine. ^[4]

How does HazCom enforcement work and what are the penalties?

Hazard communication is one of OSHA's most cited standards, year after year. It has landed in OSHA's top ten most-cited list for general industry nearly every year of the past decade. ^[5] In fiscal year 2023, violations of 29 CFR 1910.1200 drew thousands of citations across industries.

OSHA citations come in four levels: Other-than-Serious, Serious, Willful, and Repeat. HazCom violations usually land at Serious, because leaving workers in the dark about chemical hazards carries direct potential for serious harm.

As of 2024, OSHA's maximum penalties, adjusted every year for inflation under the Federal Civil Penalties Inflation Adjustment Act, are: ^[6]

• Serious or Other-than-Serious: up to $16,131 per violation
• Willful or Repeat: up to $161,323 per violation

Inspectors most often cite missing SDSs, unlabeled secondary containers, no written program, thin or undocumented training, and training run only in English for a workforce that doesn't read English.

The priciest citations come from willful or repeat violations, where an employer knew about a problem and skipped the fix, or where OSHA flagged the same issue at an earlier inspection. Being small buys no shelter from a large penalty when the violation is serious enough.

The cheapest route is the obvious one. Get compliant before the inspector shows up, not after.

How does GHS hazard communication apply to contractors and multi-employer sites?

Multi-employer worksites add a layer of coordination most small business owners don't think about until a citation forces the issue.

When outside contractors work in your facility, 29 CFR 1910.1200(e)(2) requires you to tell them about any hazardous chemicals they might be exposed to, provide SDSs on request, and pass along the precautions they need to take. ^[1] You also point them to where the SDSs live.

The contractors owe you the same in reverse. They have to tell you about the hazardous chemicals they're bringing onto your property. If a welding crew shows up with fluxes and shield gases, they hand you their SDSs. If a pest control company sprays your building, they owe you hazard information on the pesticides.

This doesn't have to be complicated. A short written exchange before the job starts, listing the chemicals each side is bringing and the precautions to take, usually covers it. Keep a copy. If something goes wrong, it shows OSHA you took coordination seriously.

Construction sites get messy because dozens of subcontractors often work at once. The general contractor usually owns the coordination role, but each sub still answers for its own employees' HazCom compliance.

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

HazCom doesn't carry the long retention rules that some OSHA standards do, but a few things still need documenting.

Training records: OSHA sets no retention period for HazCom training records inside 1910.1200 itself, but the practical standard across OSHA enforcement is duration of employment plus three years. Write down who was trained, what was covered, when it happened, and who taught it. A sign-in sheet plus a description of the content clears most inspections.

SDSs: Here there is a hard rule. Under 29 CFR 1910.1020 (the Access to Employee Exposure and Medical Records standard), an SDS for a chemical no longer in use has to be kept for 30 years. ^[7] Occupational diseases can take decades to surface. A worker exposed to a carcinogen today might not develop cancer for 20 years, and if they file a claim, that SDS may be the only record of what they handled.

Written program: Keep it current and keep it on site. No retention period covers old versions, but a dated history of your program shows OSHA you've been maintaining it over time.

Chemical inventory: No retention period sits in the regulation, but saving annual snapshots is a smart habit. It records when you added or dropped chemicals, which can matter in an exposure claim.

Where can small businesses get HazCom program templates and training materials?

OSHA gives away a lot of this for free if you know where to look.

OSHA's website has a model written hazard communication program you can adapt. ^[8] It's a real document, not a checklist, and it walks through every required element. It needs heavy customization to fit your workplace, but it's the right place to start if you're doing this yourself.

OSHA's Hazard Communication page also holds guidance documents, a pictogram reference, and small entity compliance guides that are genuinely useful. ^[4]

For training, OSHA's HazCom QuickCard series covers label reading and SDS navigation on a single page and works well as a supplement to real training. They come in English and Spanish.

The National Institute for Occupational Safety and Health (NIOSH) and state consultation programs will review your HazCom program at no cost and no penalty risk. Most states run these free on-site consultations for small businesses through OSHA's program. ^[9]

If building a program from scratch sounds like an afternoon you don't have, SafetyFolio's safety program generator walks you through a HazCom program built around your chemicals and your industry in about 15 minutes. You still review and finalize it, but the structure is done for you.

For training beyond HazCom, if your business also runs lockout/tagout, see our guide on OSHA 1910.147 affected employee training requirements.

Frequently asked questions

Is GHS hazard communication the same as OSHA HazCom?

Yes. OSHA revised its Hazard Communication Standard (29 CFR 1910.1200) in 2012 to align with GHS, and people use the two terms interchangeably. The legal standard is 1910.1200; "GHS hazard communication" describes the same rule using the name of the international framework OSHA adopted. The requirements are identical.

Who needs hazard communication training?

Any employee who may be exposed to hazardous chemicals in normal work or a foreseeable emergency must be trained before their first exposure. That takes in full-time, part-time, seasonal, and temporary workers. It includes office workers if cleaning chemicals are used in their space. The rule sets no minimum hours, only that training be effective.

Do temporary workers need HazCom training?

Yes. The staffing agency and the host employer share the duty. The staffing agency usually handles general HazCom awareness training; the host employer covers site-specific training on the actual chemicals in the worker's assigned area. OSHA has issued letters of interpretation confirming this shared responsibility for temporary workers.

How often does HazCom training need to be repeated?

OSHA requires training before initial assignment and whenever a new hazard enters the work area. There's no fixed annual retraining rule in 29 CFR 1910.1200. But when workers meet new chemicals or a process changes, you train before exposure. Many employers run annual refreshers as good practice, which is a reasonable approach.

What's the difference between an MSDS and an SDS?

MSDS (Material Safety Data Sheet) was the old term and format used before OSHA adopted GHS in 2012. An SDS (Safety Data Sheet) uses the standardized 16-section format the GHS-aligned rule requires. The SDS replaced the MSDS. If you still have MSDSs from old chemicals, swap them for current GHS-format SDSs from your supplier.

Does OSHA require SDSs to be kept in a binder, or can they be electronic?

Electronic SDS systems are allowed as long as workers can reach them at all times during a shift without barriers. OSHA requires a reliable backup for emergencies or outages. A printed binder as backup for an electronic system is a common, practical setup that meets the standard.

How long do you have to keep SDSs after a chemical is no longer used?

Under 29 CFR 1910.1020, you keep SDSs for chemicals no longer in use for 30 years. This falls under the Access to Employee Exposure and Medical Records standard, which recognizes that occupational diseases can take decades to appear. A former employee may need that exposure record long after the chemical is gone from your building.

What happens if a supplier doesn't provide an SDS?

You still have to obtain one before workers are exposed. OSHA's guidance is to contact the manufacturer directly if the distributor can't produce the SDS. If you still can't get it, stop using the chemical. An employer can't use the supplier's failure as a defense in an OSHA inspection; the duty to have SDSs on hand belongs to you.

Do small businesses with only a few chemicals still need a written HazCom program?

Yes. The written program requirement in 29 CFR 1910.1200(e) applies no matter your company size or chemical count. Even with a single hazardous chemical, you need a written program. OSHA does not scale this requirement to company size. The program can be short if your inventory is small, but it has to exist in writing.

What are the most common HazCom violations OSHA cites?

The most cited violations include missing or unreachable SDSs, unlabeled secondary containers, no written program, thin or undocumented training, and a stale chemical inventory. Training run only in English for a workforce that doesn't read English is cited more and more. Hazard communication has ranked in OSHA's top ten most-cited general industry standards for many years running.

Does HazCom apply to construction and agriculture, or only general industry?

It applies broadly. Construction falls under 29 CFR 1926.59, maritime under 29 CFR 1915.99, and agriculture under 29 CFR 1928.21. All three incorporate 29 CFR 1910.1200 by reference, so the same GHS label, SDS, training, and written program requirements apply across sectors. The core obligations are identical no matter which one you're in.

Can I use NFPA or HMIS labels instead of GHS labels?

For secondary workplace containers you fill yourself, OSHA allows alternative systems like NFPA 704 or HMIS, as long as workers are trained to read them and can reach hazard information at least as protective as a GHS label would give. For containers you receive from suppliers, you must use the supplier's GHS-compliant label as-is.

What does hazard communication mean for chemicals with trade secret ingredients?

Manufacturers can withhold specific chemical identities as trade secrets under set conditions, but they still have to disclose that a hazardous ingredient is present and the hazard information, and they must release the identity to health professionals treating an exposed worker in an emergency. OSHA's trade secret provisions sit in 29 CFR 1910.1200(i).

Sources

1. OSHA, Hazard Communication Standard 29 CFR 1910.1200: Full text and requirements of OSHA's GHS-aligned Hazard Communication Standard including label elements, SDS format, training requirements, and written program obligations
2. OSHA, Hazard Communication overview page: Approximately 32 million workers are exposed to about 650,000 hazardous chemical products at work
3. OSHA, Standard Interpretations (Letters of Interpretation): OSHA interpretation letters clarifying training language requirements for non-English-speaking workers and obligations to obtain SDSs from manufacturers
4. OSHA, Hazard Communication Pictograms page: Description of all nine GHS pictograms and their associated hazard categories
5. OSHA, Commonly Used Statistics (top ten most-cited standards): Hazard communication (29 CFR 1910.1200) has ranked among OSHA's top ten most-cited standards for general industry for many consecutive years
6. OSHA, Penalties page: As of 2024, OSHA maximum penalties are $16,131 per serious violation and $161,323 per willful or repeat violation, adjusted annually for inflation
7. OSHA, Access to Employee Exposure and Medical Records, 29 CFR 1910.1020: SDSs for chemicals no longer in use must be retained for 30 years under the access to employee exposure and medical records standard
8. OSHA, Hazard Communication page (model written program and compliance guides): OSHA provides a model written hazard communication program and small entity compliance guides that employers can adapt
9. OSHA, On-site Consultation Program for Small Businesses: OSHA's free on-site consultation program is available to small businesses and carries no penalty risk
10. UNECE, Globally Harmonized System of Classification and Labelling of Chemicals (GHS): GHS was first published by the United Nations in 2003 as a framework for standardizing chemical hazard classification and communication worldwide
11. OSHA, Hazard Communication Final Rule (77 FR 17574, 2012): OSHA adopted GHS into the federal Hazard Communication Standard through a final rule published in 2012
12. BLS, Injuries, Illnesses, and Fatalities program: Bureau of Labor Statistics data on occupational injury and illness, including chemical exposure incidents