How to write a hazard communication plan that satisfies OSHA

Last updated 2026-07-09

What is a hazard communication plan and who has to have one?

A hazard communication plan (a HazCom plan, or HazCom program) is a written document that explains how your workplace identifies hazardous chemicals, passes that hazard information to employees, and makes sure everyone working around those chemicals knows what to do. OSHA's Hazard Communication Standard, at 29 CFR 1910.1200, says the plan has to be in writing, available to employees at all times, and specific to your actual workplace. ^[1]

The rule covers almost every general industry employer. If your workers could be exposed to a hazardous chemical during normal work or in a foreseeable emergency, you are covered. That takes in the obvious places (chemical plants, auto shops, manufacturing floors) and plenty of quiet ones (restaurants with cleaning agents, offices with toner cartridges classified as hazardous, job sites using solvents). There is no small-business exemption. OSHA does not give you a pass because you have three employees.

HazCom is one of OSHA's most-cited standards, year after year. In fiscal year 2023 it ranked second on the top-ten list with 2,976 violations, behind only fall protection. ^[2] That tells you two things. Inspectors look for it, and a lot of employers still get it wrong.

The written plan does not have to be long. A small shop with a handful of chemicals might run two pages plus a chemical list and a stack of Safety Data Sheets (SDS). What matters is that it covers every required element and matches what actually happens on your floor.

What are the required elements of a hazard communication plan?

29 CFR 1910.1200(e) says the written program must describe how your workplace will meet the requirements for labels, SDS, and employee information and training. OSHA spells out the minimum content, and there are six pieces. ^[1]

1. A list of the hazardous chemicals present in the workplace (by work area, product name, or chemical identity, as long as you can cross-reference it to the SDS). 2. How you will make sure containers are labeled (including pipes, process containers, and portable containers). 3. How you will obtain, maintain, and make SDS accessible to employees. 4. How you will inform and train employees about chemical hazards. 5. How the plan covers non-routine tasks that involve hazardous chemicals. 6. How the plan handles hazardous chemicals brought in by contractors working on-site.

Those last two trip people up. Hire a painting contractor who shows up with their own solvents, and your HazCom plan has to explain how you will tell that contractor about hazards already in the building, plus how you will find out what they are carrying in. The duty runs both directions.

A few things are not required but are smart anyway: a named HazCom coordinator (someone owns this), a written step for adding new chemicals before they land on site, and a review schedule. Plans that assign responsibility by job title, not a person's name, hold up better. People leave. Titles stay.

One line inspectors quote straight from the standard: the written program must be "available, upon request, to employees, their designated representatives, the Assistant Secretary and the Director" per 29 CFR 1910.1200(e)(4). ^[1] Lock it in a manager's office and you have defeated the point of writing it.

What does a hazard communication plan example look like in practice?

Here is a stripped-down structural example of a HazCom program for a small manufacturing shop with 15 employees. Adapt it. Do not copy it word for word, because your plan has to reflect your specific workplace.

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Section 1: Purpose and scope This plan describes how [Company Name] complies with 29 CFR 1910.1200. It applies to all employees who may be exposed to hazardous chemicals at our facility at [address].

Section 2: Responsible person The HazCom coordinator is [Job Title]. This person maintains the chemical inventory list, keeps SDS current and accessible, and coordinates training.

Section 3: Chemical inventory list A current list of hazardous chemicals used at this facility is posted at [location] and kept electronically at [location]. The list is updated before any new chemical enters the workplace.

Section 4: Safety Data Sheets SDS for all listed chemicals are kept in [binder at main workstation / electronic system on shop floor terminals]. Employees on any shift can reach them without supervisor approval. When a new chemical arrives, the SDS is obtained from the supplier before first use.

Section 5: Labels All incoming containers must arrive with GHS-compliant labels. Containers stay in storage until the label is verified. Portable containers used for transfer during a shift and emptied that same shift are exempt from labeling under 29 CFR 1910.1200(f)(8). Any container that stays past that shift gets a secondary label with product name and hazard information.

Section 6: Employee training All employees get HazCom training before working with or near hazardous chemicals. Training covers the GHS system, how to read an SDS, what the labels mean, and the specific hazards of the chemicals in their work area. Records are kept for [X years].

Section 7: Non-routine tasks Before any task involving hazardous chemicals that is not part of normal operations (tank cleaning, pipe flushing, equipment maintenance), the supervisor briefs affected workers on the specific chemicals, exposure risks, and controls in place.

Section 8: Contractor coordination Before outside contractors begin work, [Job Title] will: (a) inform them of hazardous chemicals in the areas they will work, (b) request SDS for any chemicals they bring on-site, and (c) make those SDS accessible to our employees during the contract period.

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That is the skeleton. A real plan then attaches the chemical inventory list and the SDS binder or electronic access instructions. The whole document might run four to eight pages. A restaurant version would be simpler (fewer chemicals, more focus on cleaners and sanitizers). A welding shop's would add sections on welding fumes and ventilation.

If you want a plan built for your industry without starting from a blank page, SafetyFolio's safety program generator can produce a draft in about 15 minutes.

How does the GHS fit into your HazCom plan?

The Globally Harmonized System of Classification and Labelling of Chemicals (GHS) is the international framework OSHA folded into 29 CFR 1910.1200 in its 2012 update. Your plan has to address it because GHS now governs both labels and SDS in the United States. ^[1]

GHS standardized two things your plan must account for.

Labels. Every hazardous chemical container needs a label with six elements: product identifier, signal word ("Danger" or "Warning"), hazard statements, precautionary statements, pictograms, and supplier contact information. Your plan explains how you check that incoming containers carry compliant labels and what you do when one does not.

Safety Data Sheets. The old Material Safety Data Sheet (MSDS) is gone. SDS now follow a 16-section format set out in Appendix D of 29 CFR 1910.1200. Section 2 lists hazard identification, Section 8 covers exposure controls and PPE, and Section 14 covers transport. Your employees need to know how to move through this format, which is part of your training duty.

OSHA's GHS deadline for general industry was June 1, 2016. If you still have MSDS documents in your binders instead of SDS, that is a citation waiting to happen. Suppliers must provide GHS-compliant SDS, so a vendor who cannot produce one is a red flag worth writing down.

Your plan does not need a chapter on GHS theory. It needs to tell employees where hazard information sits on a label and how to read the SDS sections that matter to their work. That usually lives in your training, not in the written document itself.

What do you have to include in your chemical inventory list?

The chemical inventory list is often the first thing an OSHA compliance officer asks to see, because it anchors everything else. A chemical sitting on the floor that never made the list means the rest of your paperwork will not save you.

The list has to name every hazardous chemical present. "Hazardous" under 29 CFR 1910.1200 means a chemical classified as a physical or health hazard, a simple asphyxiant, a combustible dust, a pyrophoric gas, or a chemical with reasonable scientific evidence of hazardous effects. ^[1] Common cleaners, adhesives, paints, solvents, and many lubricants qualify. Water does not.

The format is flexible. OSHA does not require a specific template. Most small employers use a simple table:

Product Name	Manufacturer	Location Used	SDS Available?	Last Verified
Acetone (drum)	Vendor X	Paint room	Yes	2024-11
Muriatic acid	Vendor Y	Cleaning station	Yes	2024-11
WD-40 (aerosol)	WD-40 Co.	Maintenance area	Yes	2024-11

Three practical notes. Audit the list at least once a year and before any new chemical arrives. Include chemicals contractors bring in if they show up with any regularity. And skip the things that arrive and leave the same day in sealed consumer-size containers for office use (a specific exemption at 29 CFR 1910.1200(b)(6)(ix)), but keep anything your workers actively handle.

Staying current is the most commonly neglected part of HazCom. A habit that works: tie the list update to your purchasing process, so no new chemical gets ordered without a matching SDS request and inventory entry.

What are the SDS requirements under HazCom?

Safety Data Sheets carry your whole program. Under 29 CFR 1910.1200(g), you must have an SDS for each hazardous chemical in the workplace, and those SDS have to be readily accessible to employees during every shift. ^[1]

"Readily accessible" has no set distance or time in the regulation, but OSHA's letters of interpretation make clear that employees have to reach SDS information right away in an emergency. ^[4] An SDS locked in an office where only the day-shift manager holds a key fails that test.

For small employers, a binder at the workstation (organized alphabetically or by work area) is still the simplest approach. Bigger operations run electronic systems, which are fine as long as a backup exists for power outages or system crashes, and as long as employees actually know how to use them.

Key SDS duties your plan should name:

• Get SDS from suppliers before first use, not after the drum shows up.
• Keep SDS current. When a supplier revises one, update your copy. Many chemical companies push updates automatically, so your plan should say who receives them.
• Do not throw an SDS away unless you are sure the chemical is gone and no longer present. Old SDS can matter for historical exposure records if a health claim surfaces years later.
• For chemicals you make on-site, you write the SDS.

If a supplier refuses to provide an SDS for a product you believe is hazardous, OSHA says you can contact the agency for help. In practice, switching to a vendor who complies is faster.

What does HazCom training have to cover?

Training is where most small employers fall short, and it is where employees get hurt when the program fails. The requirements sit at 29 CFR 1910.1200(h). ^[1]

At a minimum, training has to cover:

• The requirements of the HazCom standard itself (employees should know their right to information).
• The chemicals present in their work area.
• The location and availability of the written plan and SDS.
• Methods used to detect hazardous chemicals (monitoring equipment, visual indicators, odor in some cases).
• Physical and health hazards of the chemicals workers encounter.
• Steps employees can take to protect themselves (engineering controls, work practices, PPE).
• How to read and use labels and SDS.

Training has to happen before an employee works with or near a hazardous chemical, not 30 days later at the next safety meeting. When a new chemical brings a hazard your existing training did not cover, you train again before exposure.

The standard requires that employees be able to demonstrate understanding, more than sit through a lecture. So your records should document the specific chemicals covered, the date, the trainer's name, and a sign-off from the employee. Sign-in sheets work. So does a short written quiz. What does not work is "we told everyone at orientation" with nothing on paper.

For structuring training across multiple safety topics, see our guide to workplace safety training.

One common myth: online-only HazCom training satisfies the standard everywhere. It can cover the knowledge pieces. But if your workers handle specific chemicals, walking them through that chemical's actual SDS and label in that workplace is good practice and hard to fake through a video.

How do you handle labeling requirements for containers at your facility?

Labeling is the most visible part of HazCom, and the easiest citation for an inspector to spot from across the room. OSHA's GHS label requirements apply to shipped containers. Your duty for in-plant containers is a little different but no less real. ^[1]

For containers shipped to you, the manufacturer supplies the GHS-compliant label. Your job is simple: do not remove or deface it, and do not let it fade past readable. If a label peels or fades, replace it.

For containers you fill or transfer on-site, the rule depends on use. Portable containers filled for immediate use by the person who filled them, in that same shift, are exempt under 29 CFR 1910.1200(f)(8). Every other secondary container needs, at minimum, the product name plus words, pictures, or symbols that give employees a general idea of the hazard (flammable, corrosive, toxic). A full GHS-compliant secondary label is always defensible. A hand-scrawled generic label is riskier.

Pipes and piping systems are their own puzzle. OSHA lets employers use process sheets, batch tickets, operating procedures, or other written materials in place of labels on stationary process containers and pipes, as long as those materials stay in the work area during every shift.

Do a labeling audit before any OSHA inspection. Walk your facility with fresh eyes. Look for spray bottles filled from bulk with no label, unmarked drums, labels buried under tape or paint, and pipes carrying chemicals with no marking at all. Every one of those is a citation.

How does HazCom apply to contractors and multi-employer worksites?

Multi-employer sites create a coordination problem a lot of small businesses ignore until an inspector shows up. The duty is real, and it is written into the standard.

Under 29 CFR 1910.1200(e)(2), employers who produce, use, or store hazardous chemicals in a way that could expose another employer's workers must make sure that other employer can reach their SDS, labeling system, and any applicable hazard information. ^[1]

In practice, this means two things.

Hire outside contractors who will work in your building, and you have to tell them about hazardous chemicals they may run into, give them access to your SDS, and explain your labeling system. Handle it in a pre-work orientation, a written safety handout, or a contractor safety agreement. The form matters less than having a record of it.

When contractors bring their own hazardous chemicals onto your site, you have the right to request SDS for those materials. Your employees may be exposed to them, so they need to know. Your HazCom plan should name who owns this exchange and how it gets documented.

Construction employers follow a parallel rule under 29 CFR 1926.59. If you run both general industry and construction operations, check which standard applies to which.

Some employers require contractors to submit an SDS and a chemical list at least 48 hours before starting work. That buys time to brief your workers and confirm you have no conflicting hazards, like reactive chemicals ending up next to each other.

What happens if OSHA cites you for HazCom violations?

HazCom violations are almost always classified as "serious" rather than willful or repeat, which caps the statutory maximum at $16,131 per violation as of 2024, after OSHA's annual inflation adjustment. ^[5] The agency usually groups related HazCom problems into a few citations instead of writing up every missing label on its own, though grouping practices vary by area office.

The common HazCom citation categories, following the standard's structure:

Citation type	What triggered it	Typical severity
No written plan	No document exists	Serious
Incomplete written plan	Missing required elements	Serious
Missing SDS	Chemical present, no SDS	Serious
Inaccessible SDS	SDS exist but locked away	Serious
Container labeling violations	Unlabeled secondary containers	Serious
Training deficiencies	No records, no coverage of specific chemicals	Serious

OSHA runs an informal conference process where you can contest citations, negotiate a reduced penalty, or work out an abatement schedule. Small employers who show a real good-faith effort (a plan exists, training happened, they just missed some labels) can often knock penalties down a lot in that conference.

Here is the number that should worry you more than the fine. OSHA's own white paper puts the average cost of a serious occupational injury above $40,000 in direct and indirect costs per incident. ^[6] A cleaning-product splash that burns an eye because nobody knew to wear goggles costs far more than a citation ever will.

How do you build and maintain a HazCom plan without a safety consultant?

You do not need a consultant to build a solid HazCom plan. You need about four hours and a clear order of operations.

Step 1: Walk your facility and list every chemical product your workers touch or could be exposed to. Cleaners, maintenance chemicals, raw materials, process chemicals, and anything contractors bring in regularly. Do not trust memory. Check storage rooms, janitor closets, maintenance carts, and the space under production equipment.

Step 2: Collect an SDS for everything on the list. Most suppliers post SDS on their website or send them on request. OSHA's free HazCom resources and NIOSH's Pocket Guide to Chemical Hazards are handy references. ^[7] For any chemical where you cannot get a supplier SDS, switch suppliers or use OSHA's resources to identify the hazards yourself.

Step 3: Write the six required elements (covered in the second section of this article). Use your own words, keyed to your facility. "SDS are kept in the red binder next to the electrical panel in the main shop" beats "SDS are kept in a readily accessible location" every time.

Step 4: Train your employees before they work with any chemical on the list. Keep records with dates, topics, and signatures.

Step 5: Set a calendar reminder to review the plan yearly, and build the habit of updating the inventory before any new product arrives.

Want a structured starting point? SafetyFolio's program generator walks you through your industry and chemical profile and produces a draft written plan in about 15 minutes, which you then review, customize, and sign.

OSHA also puts out free HazCom guidance and small-entity compliance guides worth reading. ^[8] If your operation runs genuinely complex chemical processes, a one-time consultant review to check your work is money well spent. For a shop with 10 standard chemicals, it is not.

How often do you need to update your hazard communication plan?

The standard sets no review interval. It requires that the plan stay accurate and match current conditions. In practice, you update it:

• When you add a new chemical the plan does not already cover.
• When a supplier revises an SDS in a real way (new hazard classification, changed exposure limit, different PPE recommendation).
• When your processes change in a way that shifts chemical exposures.
• When employees move into roles that put them near chemicals they did not handle before.
• When OSHA revises the HazCom standard itself.

An annual review is a reasonable baseline. Some employers fold it into their yearly safety program review. Others run a quarterly inventory check, which is better if you bring in new products often.

One trigger people miss: when OSHA adopts new permissible exposure limits (PELs), or when ACGIH updates threshold limit values (TLVs) for chemicals you use. Your SDS may lag, so check the OSHA Chemical Sampling Information database for current limits. ^[9]

The plan also has to keep up with regulatory changes. In 2024 OSHA finalized an update to 29 CFR 1910.1200 aligning it with the 7th revised edition of the GHS, with staggered compliance dates. Watch OSHA's rulemaking page and update your labels, SDS, and training as each deadline lands.

Document the review. A single line at the top of the plan, "Reviewed and updated: [date] by [title]," is your evidence of good-faith compliance.

Where can you find free HazCom templates and resources?

OSHA gives away more free HazCom material than most small employers realize. The trick is finding it on a sprawling website.

The resources worth your time:

OSHA's HazCom standard page (osha.gov) carries the full text of 29 CFR 1910.1200, all appendices (GHS classification criteria, label and SDS requirements), and links to compliance guidance. ^[1]

OSHA's Small Entity Compliance Guide for the HazCom 2012 Standard is a plain-language walkthrough of what the standard demands. It has flowcharts for figuring out your obligations. ^[8]

OSHA's Model Plans and Programs document includes a model written HazCom program you can adapt directly. ^[10] This is a real OSHA-published template, not a third-party read. It covers every required element and gives you language you can use verbatim where it fits.

NIOSH Pocket Guide to Chemical Hazards carries hazard data for hundreds of common chemicals when you need to verify a classification. ^[7]

OSHA's HazCom Letters of Interpretation are free and searchable on osha.gov. Got a specific question (does this product need an SDS? does this label element satisfy the rule?), the letters usually have your answer. ^[4]

If you are in a state-plan state (a state with an OSHA-approved plan covering private employers), your state agency often has extra resources and may differ slightly from federal HazCom rules. Check your state plan page if you are in California (Cal/OSHA), Washington (L&I), Michigan (MIOSHA), or another state-plan state. ^[11]

The hazardous communication guide on this site walks the broader regulatory picture for anyone who wants more context on how HazCom fits your overall compliance setup.

Frequently asked questions

Do I need a written hazard communication plan if I only have a few chemicals?

Yes. 29 CFR 1910.1200 has no minimum-quantity or small-business exemption. If any employee may be exposed to a hazardous chemical, you need a written plan, an SDS for that chemical, and documented training. The plan can be short (two or three pages for a small chemical count), but it has to exist and be available to employees on request.

What is the difference between an SDS and an MSDS?

Material Safety Data Sheets (MSDS) were the old format. OSHA's 2012 HazCom update replaced them with Safety Data Sheets (SDS), which follow a standardized 16-section format under the GHS. The transition deadline for general industry was June 1, 2016. If you still have MSDS documents in your binders, replace them with current GHS-compliant SDS from your suppliers.

Can I keep SDS in electronic format instead of paper binders?

Yes. OSHA allows electronic SDS systems as long as employees can reach them immediately during their shift without a supervisor's help, and a backup exists for power outages or system crashes. The system also has to work during emergencies. Paper backups for at least your most hazardous chemicals are a reasonable safeguard.

How do I handle a chemical where no SDS exists or the supplier won't provide one?

If a supplier cannot or will not provide an SDS for a product you believe is hazardous, OSHA says you can contact the agency for help. In practice, your fastest options are switching to a supplier who complies, checking whether a comparable product has an SDS you can adapt (with the actual supplier's confirmation), or calling your OSHA area office. Do not run a chemical with no hazard information.

What are the GHS pictograms and do my employees need to know all of them?

There are nine GHS pictograms: flame, flame over circle (oxidizer), exploding bomb, gas cylinder, corrosion, skull and crossbones, health hazard, exclamation mark, and environmental hazard. Your employees need to understand the ones tied to chemicals in their work area. HazCom training should cover all nine at a basic level so workers recognize any label they run into.

Do I need to train employees again when a new chemical is introduced?

Yes, if the new chemical carries a hazard your existing training did not cover. 29 CFR 1910.1200(h)(1) requires training when new physical or health hazards enter the work area. If the new chemical fits a hazard category already covered (say, another common solvent), a brief update and SDS review may be enough. When in doubt, document the extra training anyway.

What is the penalty for not having a hazard communication plan?

Serious violations of 29 CFR 1910.1200 carry a maximum penalty of $16,131 per violation as of 2024, after OSHA's annual cost-of-living adjustment. Willful or repeat violations can reach $161,323. In practice, OSHA often groups related HazCom problems, and penalties for smaller employers with no prior history are frequently cut through the informal conference process.

Does HazCom apply to construction sites?

Yes, under a parallel standard: 29 CFR 1926.59 for construction work. The substantive requirements nearly match 29 CFR 1910.1200. Written plan, SDS, labeling, and training all apply. Multi-employer construction sites add contractor coordination duties, since several employers and their chemicals often share the same space at once.

What chemicals are exempt from the HazCom standard?

The standard lists specific exemptions at 29 CFR 1910.1200(b)(6), including hazardous waste regulated by EPA, tobacco products, wood or wood products not processed in a way that releases hazardous particles, articles (solid objects that do not release hazardous chemicals under normal use), consumer products used the way a consumer would use them, and foods and drugs in the workplace. Cleaners, paints, and lubricants are almost never exempt.

How does the HazCom plan address non-routine tasks like equipment cleaning or tank entry?

29 CFR 1910.1200(e)(1)(ii) requires the written plan to describe how you will inform employees of hazards tied to non-routine tasks involving hazardous chemicals. In practice, that means a pre-task briefing or job hazard analysis before the work starts, covering the specific chemicals, potential exposures, and protective measures. Document these briefings separately from your regular training records.

Is a hazard communication plan the same thing as a hazard communication program?

They are the same thing. The standard uses the term 'written hazard communication program' at 29 CFR 1910.1200(e). Employers, industry guides, and OSHA publications also call it a 'hazard communication plan.' Either term describes the written document explaining how your workplace meets the standard's requirements for labels, SDS, and training.

How long do I have to keep HazCom training records?

The HazCom standard sets no retention period for training records. But OSHA's Access to Employee Exposure and Medical Records standard (29 CFR 1910.1020) requires exposure records be kept for 30 years. To stay safe, many employers hold HazCom training records for at least five years and exposure monitoring records for the full 30 years that 1910.1020 requires.

What is OSHA's model hazard communication program and how do I use it?

OSHA publishes a Model Plans and Programs document with a fill-in-the-blank hazard communication program template. It covers every required element: purpose, chemical inventory, SDS procedures, labeling, training, and contractor coordination. Use it as a starting point, customize it to your actual facility and chemicals, then sign it as your official written program. Find it on osha.gov under the HazCom compliance resources.

Sources

1. OSHA, Top 10 Most Frequently Cited Standards, FY 2023: Hazard Communication was the second most-cited OSHA standard in fiscal year 2023 with 2,976 violations
2. OSHA, Letters of Interpretation on Hazard Communication: OSHA letters of interpretation on SDS accessibility, labeling, and other HazCom requirements
3. OSHA, Penalties: Maximum penalty for a serious OSHA violation is $16,131 as of 2024 after annual cost-of-living adjustment
4. OSHA, Injury and Illness Prevention Programs White Paper (OSHA 3885): OSHA estimates the average cost of a serious occupational injury at over $40,000 in direct and indirect costs per incident
5. NIOSH, Pocket Guide to Chemical Hazards: NIOSH Pocket Guide provides hazard information for hundreds of common workplace chemicals
6. OSHA, Small Entity Compliance Guide for the Revised Hazard Communication Standard (OSHA 3695): OSHA's plain-language compliance guide for the HazCom 2012 standard, including flowcharts for employer obligations
7. OSHA, Chemical Sampling Information / Annotated PELs: OSHA's Chemical Sampling Information database lists current permissible exposure limits for regulated chemicals
8. OSHA, Model Plans and Programs for the OSHA Bloodborne Pathogens and Hazard Communications Standards (OSHA 3186): OSHA publishes a model written hazard communication program template that employers can adapt
9. OSHA, State Plans page: States with OSHA-approved state plans may vary slightly from federal HazCom requirements; employers there should check their state agency
10. OSHA, Hazard Communication Standard, 29 CFR 1910.1200: The Hazard Communication Standard requires a written program, chemical inventory, SDS access, container labeling, and employee training