Hazardous material communication and training programs: the complete OSHA guide

Last updated 2026-07-09

What does OSHA's Hazard Communication Standard actually require?

The Hazard Communication Standard, at 29 CFR 1910.1200, is OSHA's rule for making sure workers know which chemicals they handle and what those chemicals can do to them. ^[1] It's been on the books since 1983. OSHA revised it in 2012 to match the United Nations Globally Harmonized System (GHS) of Classification and Labelling of Chemicals, and it reaches almost every general industry employer in the country that keeps hazardous chemicals on site.

The standard has five parts. A written HazCom program. Safety Data Sheets (SDSs) for every hazardous chemical you use or store. Labels on every container. Trained workers. And all of it working together as a system, not a binder of paper nobody opens.

Chemical manufacturers and importers carry the first load. They evaluate chemicals for hazards, write the SDSs, and put GHS labels on containers before shipping. The businesses buying and using those chemicals carry the rest: keep the SDSs accessible, keep containers labeled, train the crew. That split trips up a lot of small businesses. They assume the supplier's label is the finish line. It isn't. ^[1]

The definition of "hazardous chemical" is wide. Under 29 CFR 1910.1200(b), it covers any chemical that poses a physical or health hazard, plus simple asphyxiants, combustible dust, pyrophoric gases, and chemicals with unknown hazards. That sweeps in most of what sits in a normal workplace: cleaning solvents, welding gases, spray paints, adhesives. ^[1]

The rule you follow depends on your industry. General industry uses 29 CFR 1910. Construction has its own version at 29 CFR 1926.59, and maritime has one at 29 CFR 1915.99, but all three say substantively the same thing. In a state with an OSHA-approved State Plan, you follow a state rule that has to be at least as effective as the federal one. ^[2]

Why is HazCom the most-cited OSHA standard year after year?

HazCom lands first or second on OSHA's annual top-10 violations list nearly every year. ^[3] In fiscal year 2023, OSHA wrote 2,886 HazCom citations across general industry. The rule isn't obscure. The violations are just easy to spot during a walkthrough, and too many employers treat the written program as a one-and-done paperwork chore instead of something that stays alive.

The repeat offenders are predictable. No written program, or a generic one that never names the chemicals actually on site. SDSs missing or locked away where workers can't reach them. Containers with no label, or labels faded past reading. Training that happened at hire and never got updated when new chemicals showed up. Each one is a separate citable condition, so a single inspection can generate a stack of violations from one facility.

Serious violations currently run up to $16,131 each, and willful or repeated violations reach $161,323. ^[3] OSHA raises those numbers for inflation every year. For a small shop, a handful of serious HazCom citations can land in the $30,000 to $80,000 range even after the size adjustment. Businesses with 25 or fewer employees usually get a 60 percent reduction, and that still leaves real money on the table.

The fines aren't the whole story. The Bureau of Labor Statistics reported that in 2022, more than 50,000 workers had occupational illnesses tied to exposure to harmful substances or environments. ^[4] Chemical exposures drive a big share of those. Many involve chemicals whose hazards are well understood, where a clear label and honest training would have cut the risk.

What goes into a written HazCom program?

Under 29 CFR 1910.1200(e), your written program has to cover three things at minimum: how you handle labels and warnings, how you maintain SDSs, and how you train workers. ^[1] A program that touches those three at a generic level still gets cited, because the standard wants the program tied to your specific workplace.

Here's what a solid written program actually needs.

A chemical inventory. List every hazardous chemical in your facility by product name and by the identity used on the SDS. This inventory is the spine of the whole thing. If you don't know what you have, you can't train on it, label it, or keep SDSs for it. Some people do a walkthrough with a clipboard; others run chemical management software. Both work, as long as the list stays current.

Label requirements. Describe how you check incoming containers for GHS labels, what happens when a label is missing or torn, and how you handle secondary containers (the smaller bottles or tanks you fill from a bigger one). GHS labels carry a product identifier, a signal word (Danger or Warning), hazard statements, precautionary statements, pictograms, and supplier contact information. ^[1]

SDS access procedures. Spell out where SDSs live and how workers on every shift reach them during their work hours. Paper binders, an electronic system, or both. The word that matters is "immediate." A worker who's injured or caught in a chemical incident can't wait while someone hunts for a password. ^[1]

Training procedures. Name who trains, when (before first assignment and whenever a new hazard arrives), what the training covers, and how you document it.

Non-routine tasks. If workers occasionally do jobs that expose them to hazards outside normal operations, like cleaning a tank, pressure-testing a line, or stripping old coatings, the program has to address those by name.

Contractor coordination. Outside contractors in your facility get SDSs for the chemicals they might run into. They owe you the same for anything they bring in.

A good written program runs about 5 to 12 pages for most small businesses. Longer isn't better. If a person can't read it and follow it in 20 minutes, it's too long. SafetyFolio's safety program generator builds a customized HazCom written program in about 15 minutes, which helps if you're starting cold or an inspector just flagged your current document.

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

Safety Data Sheets replaced Material Safety Data Sheets (MSDSs) when the GHS-aligned HazCom revision took full effect on June 1, 2016. ^[1] The format is fixed: every SDS has exactly 16 sections in the same order, no matter which manufacturer wrote it. That's a genuine gain over the old MSDS days, when formats varied wildly and a worker under stress couldn't count on finding what they needed.

Here's what each section holds.

Section	Content
1	Identification (product name, manufacturer, intended use, emergency phone)
2	Hazard identification (GHS classification, signal word, hazard statements, pictograms)
3	Composition / ingredients (chemical names and CAS numbers, trade secret exceptions)
4	First aid measures (routes of exposure and response steps)
5	Firefighting measures (suitable extinguishing agents, special hazards)
6	Accidental release measures (spill response, containment, cleanup)
7	Handling and storage (safe handling practices, storage conditions)
8	Exposure controls / PPE (OSHA PELs, ACGIH TLVs, required respiratory and skin protection)
9	Physical and chemical properties (flash point, vapor pressure, appearance, etc.)
10	Stability and reactivity (conditions to avoid, incompatible materials)
11	Toxicological information (routes of exposure, acute and chronic health effects)
12	Ecological information (not required by OSHA but required by EPA for some chemicals)
13	Disposal considerations
14	Transport information
15	Regulatory information (SARA Title III lists, state right-to-know laws)
16	Other information (revision date, preparation date)

For training, Sections 2, 4, 6, 7, 8, and 10 are the ones workers need to understand and find fast. Section 8 carries extra weight because it names the required PPE, including the type of respiratory protection if any is needed.

You need an SDS for every hazardous chemical in the workplace. You get them from the manufacturer or supplier, usually a download off their website. Keep them current. Manufacturers update SDSs when new hazard information surfaces, and the current version is the one you're required to have. A habit that works: every time you reorder a chemical, check whether the SDS has changed since your last download. ^[1]

What must HazCom training actually cover?

This is where employers stumble. They play a 20-minute generic chemical safety video at onboarding, pass around a sign-off sheet, and call it done. That's not compliant. Under 29 CFR 1910.1200(h), training has to cover the requirements of the HazCom standard itself; the operations in the employee's work area where hazardous chemicals are present; where the written program and SDSs live and how to get them; the methods workers can use to detect the presence or release of a hazardous chemical; the physical, health, simple asphyxiation, combustible dust, and pyrophoric hazards involved; the steps workers can take to protect themselves; and the details of the labeling system plus how to read an SDS. ^[1]

The standard wants the training built around the chemicals actually in that worker's area. A forklift operator who fuels with propane and uses a solvent-based cleaner needs training on propane and that solvent, not a lecture on the periodic table.

Training happens before initial assignment. If a worker will handle or work near a hazardous chemical on day one, the training comes before day one. Retraining kicks in whenever a new physical or health hazard enters the work area, which means buying a new chemical product triggers a training obligation if that product brings a hazard the crew hasn't seen before. ^[1]

OSHA doesn't set a minimum training length or require a test. What it wants is proof that workers actually understand the material. A documented question-and-answer session, a worker demonstrating how to read an SDS, or a written quiz all count as evidence. A sign-off sheet by itself proves attendance, not comprehension.

Where workers speak limited English, OSHA's position, stated in several letters of interpretation, is that training has to be delivered in a language and manner employees can understand. Running English-only training for a crew where five workers speak mainly Spanish is not compliant. ^[5]

For how chemical training fits your wider training duties, see our guide to workplace safety training.

For the full picture on the HazCom standard beyond training, see our breakdown at hazardous communication.

How do GHS pictograms and labels work?

GHS labels are the front line. Every container of a hazardous chemical that leaves a manufacturer carries a GHS-compliant label, and as the employer you keep those labels on the containers, legible, and undefaced. ^[1]

The nine GHS pictograms are standardized red-bordered diamonds, each standing for a category of hazard:

• Flame: flammable liquids, solids, aerosols, and self-reactive substances
• Flame over circle: oxidizers
• Exploding bomb: explosives and self-reactive substances
• Skull and crossbones: acute toxicity (severe)
• Exclamation mark: skin and eye irritation, respiratory sensitization, acute toxicity (less severe)
• Corrosion: skin and eye corrosion, metals corrosion
• Gas cylinder: gases under pressure
• Health hazard: carcinogens, reproductive toxicants, respiratory sensitizers
• Environment: aquatic hazards (optional under OSHA's rule, but common)

Signal words are either "Danger" (more severe) or "Warning" (less severe). A chemical carries only one signal word. If several hazards apply, the more severe word wins.

For secondary containers, meaning anything you fill from the original manufacturer's container, you need at minimum a product identifier plus words, pictures, or symbols that give general information about the hazards. The full GHS label format is recommended for secondary containers, but the floor is the product identifier plus hazard information. Plenty of facilities use blank label templates or a system like NFPA 704 diamonds, which works as long as the hazard information is actually present and workers are trained on the system. ^[1]

Pipes, process equipment, and production tanks fall under the labeling requirements too. Alternative systems (ANSI Z535, NFPA 704, and others) are acceptable, but they have to appear in your written program and workers have to be trained on them.

What are the specific rules for contractor and multi-employer worksite situations?

Sites where outside contractors work alongside regular employees create a two-way duty that a lot of employers miss. Under 29 CFR 1910.1200(e)(2), an employer who produces hazardous chemicals or hosts outside workers in the facility has to make SDSs available to those workers and fold chemical hazard information into site-specific training or orientation. ^[1]

In practice: you run a plant, a maintenance contractor comes in to service equipment, so you tell them which hazardous chemicals they might meet and give them the relevant SDSs. The contractor tells you about any hazardous chemicals they're bringing in, so you can pass that to your own workers.

Most people handle this with a contractor safety orientation checklist that carries HazCom-specific line items. The contractor signs it, you keep a copy, and both sides know what chemicals are in play. That's a real exchange of information that protects workers on both sides, not a box-ticking exercise.

On complex multi-employer sites, OSHA's multi-employer citation policy can make you liable for a hazard a contractor created on your site if you knew or should have known about it. HazCom hazards are among the most visible things going, so don't treat the contractor's compliance as your shield. ^[6]

How does the trade secret exception work under HazCom?

A manufacturer can sometimes withhold the specific chemical identity of an ingredient if it's a genuine trade secret, but the hazard information still has to appear on the SDS. ^[1] OSHA's line is that a trade secret claim never overrides a worker's right to know the hazards. It only lets the manufacturer keep the exact chemical name confidential in Section 3, and only under set conditions.

Health professionals, meaning physicians, industrial hygienists, and emergency responders, can obtain the specific chemical identity even for a trade secret ingredient when there's a real need tied to treatment. In a non-emergency, that usually takes a written confidentiality agreement. In an emergency, the information has to be disclosed right away, and the confidentiality agreement can follow after. ^[1]

For most small businesses this rarely comes up. If you're buying commercial chemical products, the ingredients are usually disclosed on the SDS anyway. Trade secret claims show up most in specialty formulations where a manufacturer is protecting a proprietary process.

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

HazCom itself sets no fixed retention period for SDSs while a chemical is in use. You just keep them accessible while the chemical is in the workplace. But a connected requirement under 29 CFR 1910.1020, the Access to Employee Exposure and Medical Records standard, matters here.

Under 29 CFR 1910.1020(d)(1)(ii), employee exposure records, which include records relevant to monitoring hazardous chemical exposures, have to be kept for at least 30 years. ^[7] When a chemical drops out of use, you're supposed to keep its SDS for 30 years if it could help document a past exposure. Many employers keep a historical SDS file, often electronic, for chemicals they've used and discontinued.

The HazCom standard doesn't pin a retention period on training records, but OSHA's general recordkeeping guidance and the reality of inspections both point to keeping them at least three years, longer for chemicals with chronic health risks. If a worker later claims an occupational illness from a chemical exposure and asks whether they were trained, you want the paper.

Worth keeping: dated training rosters with employee signatures, an outline of what the training actually covered, the instructor's name and qualifications, and any quiz or evaluation results. Store these apart from the written HazCom program, organized by date.

How do State Plan states differ from federal OSHA on HazCom?

Twenty-nine states and two territories run OSHA-approved State Plans covering some or all private-sector employers. ^[2] A State Plan has to adopt standards "at least as effective as" the federal one, and it can go further. A few states have done exactly that on chemical hazard communication.

California's Division of Occupational Safety and Health (Cal/OSHA) has its own Hazard Communication regulation at Title 8, Section 5194, which mirrors the federal GHS standard but also pulls in California's Safe Drinking Water and Toxic Enforcement Act (Proposition 65). Under Prop 65, a business with 10 or more employees has to give a "clear and reasonable warning" before knowingly exposing anyone to a chemical on the Prop 65 list. ^[8] That list runs past 900 chemicals. In California, HazCom compliance means both the Cal/OSHA regulation and the Prop 65 framework.

Washington State (L&I) and Oregon (OR-OSHA) also carry their own HazCom rules that track the federal standard closely. If you operate in a State Plan state, check the state agency's own website for amendments or additions past the federal baseline. The OSHA State Plans page lists every approved state and its agency contacts. ^[2]

If your business crosses state lines, the safe move is to build your written program to the strictest standard you're subject to, then note where individual states add requirements.

How should you build a HazCom training program step by step?

Here's a sequence that works for most small businesses. It's not the only one, but it hits everything OSHA requires without turning the job into a project.

Step 1: Finish your chemical inventory. Walk every area with a list. Include the obvious (drums of solvent, welding gases) and the easy-to-miss (cleaning products under the sink, aerosol lubricants in the maintenance shop, battery acid near the forklift). Give one person the inventory to own and update whenever a new product lands.

Step 2: Get and organize SDSs. Download the current SDS from each manufacturer's site for every chemical on your list. Keep them in a binder at each work area, or in an electronic system with terminals or tablets reachable on every shift. Index them alphabetically by product name.

Step 3: Write or update the written program. Point to your actual chemical inventory, your actual labeling system, and the actual spot your SDSs sit. A generic program that could describe any facility in America won't satisfy an inspector.

Step 4: Design the training. Split it in two: the general HazCom overview (the standard, the labeling system, how to read an SDS, what the pictograms mean) and chemical-specific training for each work area. The chemical-specific part is what most programs skip.

Step 5: Train before initial assignment. Document it. Get signatures. Keep the records.

Step 6: Train on new chemicals. Every time a new product with a new hazard arrives, train the affected workers before they use it.

Step 7: Review the program every year. Confirm the inventory is current, the SDSs are accessible and up to date, the labels are intact, and the training records are complete. Many employers tie this to the same annual review they run on their other OSHA written programs.

If you want a written program already built around these steps and specific to your industry, SafetyFolio generates a customized HazCom program in about 15 minutes. It won't replace a qualified safety professional for complex chemical operations, but for most small businesses with a straightforward inventory, it's a solid start.

For how HazCom sits inside your broader safety and health duties, see our piece on what a safety and health program should include.

What are common HazCom audit findings and how do you fix them?

OSHA compliance officers follow a predictable path on a HazCom inspection. Knowing what they hunt for lets you self-audit before they arrive.

Finding 1: Written program exists but isn't site-specific. Fix: add a section that names your actual chemicals, describes your actual SDS storage spot, and describes your actual labeling approach. Two paragraphs bolted onto a generic program often does it.

Finding 2: Chemical inventory is stale. Fix: give one person the job of updating it every time a new product is ordered. Tie it to purchasing.

Finding 3: SDSs missing for chemicals in use. Fix: audit your chemicals against your SDS records. The missing ones take about five minutes each to download from the manufacturer's site. If you can't find one, call the manufacturer; they're required to provide it.

Finding 4: Secondary containers unlabeled. Fix: buy a roll of blank chemical labels, set up a label station in each work area, and write "label unlabeled containers" into the program as a required step. Train supervisors to spot-check.

Finding 5: Training records incomplete or generic. Fix: keep a template training log with date, trainer name, chemicals covered, and employee signatures. Scan or photograph the signed logs into a digital folder.

Finding 6: Workers can't explain the labeling system or find an SDS on request. This one says your training is name-only. Fix: follow formal training with a short practical exercise where a worker locates the SDS for a chemical they use and reads out what Section 8 says about PPE.

Self-auditing once a year catches most of these before an inspector does. An hour of your time reviewing records costs essentially nothing next to a single serious citation.

Frequently asked questions

Does OSHA's HazCom standard apply to small businesses with fewer than 10 employees?

Yes. Unlike some environmental regulations (such as EPA's Tier II reporting, which exempts very small facilities), OSHA's HazCom standard at 29 CFR 1910.1200 has no employee-count exemption. Any employer with workers exposed to hazardous chemicals must comply, regardless of size. The only exception covers chemicals used in a household quantity and manner.

How often do workers need to be retrained on hazardous chemical communication?

OSHA sets no fixed annual retraining requirement for HazCom. Training is required before initial assignment and whenever a new physical or health hazard enters the work area. Most safety professionals still recommend at least an annual refresher, and if your chemical inventory changes often, training should track those changes. Document every training event with dates and chemicals covered.

Can Safety Data Sheets be kept electronically instead of in paper binders?

Yes. OSHA allows electronic SDS systems as long as workers reach them immediately during their shift with no barriers like a forgotten password or a device that's always in use. You also need a backup for power outages or system failures (a binder, a printed set). The standard is immediate access; the medium is secondary.

What's the difference between an SDS and the old Material Safety Data Sheet?

MSDSs were the predecessor format, with no standard layout. SDSs replaced them under OSHA's 2012 GHS-aligned HazCom revision. Every SDS carries exactly 16 sections in the same order, making information much faster to find. The full compliance deadline for the SDS format was June 1, 2016. If you still have MSDSs in your binder for current chemicals, get updated SDSs from the manufacturer.

Do office workers who use common cleaning products need HazCom training?

OSHA's HazCom standard has a partial exemption for consumer products used in the same manner and frequency as a normal consumer would. A bottle of glass cleaner an office worker uses occasionally probably doesn't trigger full training. But a cleaning crew using that same product in commercial quantities and frequency does. When in doubt, run the training; the cost is low and the protection is real.

What penalties does OSHA issue for HazCom violations?

As of 2024, OSHA can issue up to $16,131 per serious violation and up to $161,323 per willful or repeated violation. Businesses with 25 or fewer employees usually receive a 60 percent penalty reduction, but that still leaves real exposure when several violations are cited together. HazCom is OSHA's most-cited standard most years, so inspectors know exactly where to look.

Are there special HazCom rules for flammable and combustible liquids?

Flammable liquids fall under HazCom's labeling and SDS requirements and also under 29 CFR 1910.106, which sets storage and handling rules. Training should hit both the chemical hazards (per HazCom) and the physical handling requirements (per 1910.106). The GHS flame pictogram shows up on flammable liquid labels, and workers should know what it means and which storage and ignition-source controls apply.

What happens if a manufacturer refuses to provide an SDS for a product I use?

Chemical manufacturers and importers are legally required to provide SDSs to downstream users on request. If a supplier won't produce one, you can report the refusal to OSHA, go straight to the chemical manufacturer instead of the distributor, or swap the product for one with a complete SDS. You cannot keep using a chemical in your workplace without an SDS just because the supplier went quiet.

Does HazCom training need to be in-person or can it be online?

OSHA doesn't require in-person HazCom training. Online and video-based training is fine as long as it covers all the required content and is specific to the chemicals in your workplace. The catch is the chemical-specific component: generic online courses cover the HazCom framework well but can't know which chemicals your workers handle. Pair online delivery of the general material with site-specific instruction on your actual inventory.

How do I handle HazCom compliance when workers speak different languages?

OSHA's letters of interpretation make clear that HazCom training has to be delivered in a language and manner workers can understand. You don't need a bilingual instructor for every session, but you do need to confirm comprehension. Options include bilingual materials, a bilingual co-trainer, or translated documents paired with an interpreter. Document which language or method was used for each session.

What's the relationship between HazCom and OSHA's specific chemical standards like for asbestos or lead?

OSHA has substance-specific standards for some highly hazardous chemicals, including asbestos (29 CFR 1910.1001), lead (29 CFR 1910.1025), and benzene (29 CFR 1910.1028). Those carry their own training and exposure monitoring requirements that go beyond HazCom. HazCom still applies as a baseline, but the substance-specific standard controls where the two conflict. If you use any substance with its own OSHA standard, you comply with both.

Do I need a HazCom program if my employees only handle hazardous chemicals occasionally?

Yes. Frequency of exposure doesn't erase the obligation. What matters is whether a hazardous chemical is present and whether employees could be exposed. Occasional exposure can still cause acute or chronic harm. The training might be shorter and more focused when exposure is limited, but the written program, SDS access, and labeling requirements all still apply.

Sources

1. OSHA, Hazard Communication Standard (29 CFR 1910.1200): Requirements for written HazCom programs, GHS-compliant labels, 16-section SDSs, worker training before initial assignment, and coverage of hazardous chemicals broadly defined
2. OSHA, State Plans page: 29 states and territories operate OSHA-approved State Plans that must be at least as effective as the federal standard
3. OSHA, Top 10 Most Cited Standards (FY2023): HazCom (1910.1200) ranked among the top-cited standards in FY2023 with 2,886 citations; penalty ceilings of $16,131 per serious and $161,323 per willful/repeated violation
4. Bureau of Labor Statistics, Employer-Reported Workplace Injuries and Illnesses 2022: In 2022, over 50,000 workers suffered occupational illnesses involving exposure to harmful substances or environments
5. OSHA, Letters of Interpretation on HazCom Training in Languages Other Than English: OSHA's position that HazCom training must be conducted in a language and manner that employees can understand
6. OSHA, Multi-Employer Citation Policy (CPL 02-00-124): Under the multi-employer citation policy, host employers can be cited for hazards created by contractors on their site if they had or should have had knowledge
7. OSHA, Access to Employee Exposure and Medical Records (29 CFR 1910.1020): Employee exposure records related to hazardous chemical exposure must be kept for at least 30 years under 29 CFR 1910.1020(d)(1)(ii)
8. California OEHHA, Proposition 65: California's Prop 65 requires businesses with 10 or more employees to provide clear and reasonable warnings before exposing anyone to chemicals on the Prop 65 list of over 900 substances
9. OSHA, Hazard Communication / GHS section: HazCom was revised in 2012 to align with the United Nations GHS; the nine GHS pictograms and 16-section SDS format are standardized