OSHA HazCom standard: what every employer must know

Last updated 2026-07-09

What is the OSHA HazCom standard and who does it cover?

The Hazard Communication Standard, at 29 CFR 1910.1200, is OSHA's rule that workers have a right to know about the hazardous chemicals they work around. ^[1] It applies to any employer whose workers may be exposed to hazardous chemicals under normal operating conditions or in a foreseeable emergency. That means manufacturers, distributors, retailers, construction contractors, healthcare facilities, auto shops, farms above a certain size, and thousands of other workplaces.

The standard has a general industry version (29 CFR 1910.1200), a construction version (29 CFR 1926.59), a maritime version (29 CFR 1915.99), and an agriculture version (29 CFR 1928.21). All four adopt the same requirements. Learn one and you know all four. ^[1]

HazCom is one of the two most-cited OSHA standards year after year. In fiscal year 2023 it ranked second overall with 2,882 violations across all industries. ^[2] That number matters because each citation can carry its own penalty, and willful or repeat violations can reach $161,323 per instance under the 2024 penalty adjustments. ^[3]

The policy behind it is simple. If a worker is exposed to a chemical, they should know what it is, what it can do to their body, and how to protect themselves. Every requirement in the standard traces back to that one idea.

What changed when OSHA updated HazCom to align with GHS?

Before 2012, the old HazCom rule let chemical manufacturers pick their own hazard classification systems and label formats. A worker changing jobs could see completely different label symbols for the identical chemical. OSHA closed that gap in 2012 by aligning the standard with the United Nations Globally Harmonized System of Classification and Labelling of Chemicals, known as GHS. ^[1]

The latest update landed in 2024. OSHA issued a revised final rule effective July 19, 2024, with phased compliance dates running into 2026. ^[4] The 2024 revision brought the U.S. into line with the 7th revised edition of GHS and patched gaps the agency found in the 2012 version, including clearer rules for bulk shipments, better coverage of consumer-sized packages used at work, and updated physical hazard classes.

For most small employers, the 2024 changes come down to one job: review your current SDS library and label formats and confirm they meet the updated hazard class definitions. Chemical manufacturers and importers have until January 19, 2026, to comply with the new classification and labeling rules. Downstream employers (the ones who receive and use chemicals) have until July 19, 2026, to update their written programs and training to match the new SDSs and labels. ^[4]

GHS brought two changes workers notice right away. Standardized pictograms (the red-bordered diamonds) and standardized signal words, either "Danger" for more severe hazards or "Warning" for less severe ones. Those replaced the patchwork of old MSDS sheets and one-off label systems.

What are the four core requirements of a HazCom program?

The standard sorts employer obligations into four areas. Miss any one and you have a citation-worthy gap.

1. Written hazard communication program. You must have a written program specific to your workplace. ^[1] A downloaded template that still reads "[Company Name Here]" does not count. The written program has to describe how you meet each element: how you handle labeling, where SDSs live, how training happens, and what you do for non-routine tasks and contractor coordination. It must list the hazardous chemicals present in each work area, or point to where that list is kept.

2. Safety Data Sheets (SDSs). You need an SDS for every hazardous chemical in your workplace, and those SDSs must be readily accessible to workers on every shift. ^[1] "Readily accessible" means during each work shift, in the work area, with no barriers. A binder locked in a manager's office fails the test. Electronic access is fine, but only with a reliable backup for power outages or equipment failure. SDSs follow a mandatory 16-section format under GHS.

3. Labels. Every container of a hazardous chemical must be labeled, tagged, or marked with six required elements: product identifier, signal word, hazard statement(s), precautionary statement(s), pictogram(s), and the name and contact information of the manufacturer or importer. ^[1] Portable containers you fill and use up within the same shift are exempt. Any container that leaves your hands, sits overnight, or gets passed to another worker has to be labeled.

4. Employee training. Workers must be trained before their first assignment to work with hazardous chemicals. Training has to cover the requirements of the HazCom standard, the operations in their work area where chemicals are present, the location of the written program and SDSs, how to detect a chemical release, the physical and health hazards of the chemicals, and the protective measures available. ^[1] Training does not have to go chemical by chemical. It can be category-based, grouping chemicals by hazard type.

Those four pillars hold each other up. The written program documents your approach, the SDS library carries the detailed data, the labels give the at-a-glance warning, and training helps workers actually use all of it.

What must a written HazCom program contain?

OSHA's standard says the written program has to describe how you address labeling, SDSs, and employee training, and it must include a list of the hazardous chemicals known to be present in the workplace. ^[1] Beyond those minimums, inspectors look for a few specific things during a walk-through.

The program should name the person responsible for each element, say where SDSs are located (and any backup access method), describe how you handle labeled containers arriving from suppliers, explain your procedure for multi-employer worksites where contractors bring their own chemicals, and describe how you handle non-routine tasks that expose workers to new chemicals.

The non-routine task piece catches people off guard. Say your maintenance crew normally works with cleaning solvents already covered by training, but once a year they drain and clean a tank holding residue from a different chemical. That one-off exposure has to be addressed in your written program, either through documented training before each event or another defined procedure.

For multi-employer worksites, you must give contractors SDSs for any chemicals they may be exposed to in your facility, and contractors owe you the same for chemicals they bring in. ^[1] A written protocol for swapping that information before work starts keeps both sides compliant.

Here's the honest bar: a real program describes your workplace, a fake one describes nobody's. If you want one that fits, SafetyFolio's safety program generator builds a HazCom program specific to your industry and chemical inventory in about 15 minutes. Inspectors can tell the difference between a real program and a fill-in-the-blank download, and they read for it.

How do GHS labels work and what exactly must be on them?

A compliant GHS label carries six mandatory elements. ^[1] Here they are and what each one means in practice.

Product identifier. The name or number used on the SDS. If the SDS calls it "Hydrochloric Acid 37%," the label must use that same name or number so a worker can match the label to the sheet.

Signal word. Either "Danger" (more severe hazard category) or "Warning" (less severe). One product gets one signal word. If it falls into multiple hazard classes, you use the most severe word that applies.

Hazard statement(s). Standardized phrases describing the nature and degree of hazard, such as "Causes severe skin burns and eye damage." GHS assigns these by hazard category. Manufacturers do not write them freestyle.

Precautionary statement(s). Instructions for preventing harm, such as "Wear protective gloves, protective clothing, eye protection, face protection."

Pictogram(s). One or more of the nine standardized GHS pictograms in red-bordered diamonds. The flame signals flammability, the skull and crossbones signals acute toxicity, the exclamation mark signals lesser acute hazards. Manufacturers pick pictograms based on the chemical's classification.

Supplier identification. Name, address, and phone number of the manufacturer, importer, or other responsible party.

Workplace labels on secondary containers (a chemical you pour into a spray bottle, say) do not need all six elements. At minimum they need a product identifier and general hazard information. ^[1] Still, the cleanest practice is to use the full six-element label even on secondaries. It kills confusion during an inspection or an incident investigation.

One thing small employers get wrong constantly. When a shipment arrives, you are not required to relabel supplier containers unless the labels are missing, illegible, or non-compliant. Leave the supplier's GHS label intact and you're fine.

What is a Safety Data Sheet and what are the 16 sections?

An SDS is the technical document a chemical manufacturer or importer must prepare and ship with every hazardous chemical. Under GHS, every SDS follows a 16-section format in a fixed order. ^[1] That standardization means a worker who learns to read one SDS finds the same information in the same place on every SDS after it.

Here are the 16 sections and what each covers.

Section	Title	Key content
1	Identification	Product name, intended use, manufacturer contact
2	Hazard(s) identification	Signal word, hazard statements, pictograms
3	Composition/information on ingredients	Chemical identity, CAS number, concentration
4	First-aid measures	Symptoms, immediate treatment by exposure route
5	Fire-fighting measures	Extinguishing media, special hazards
6	Accidental release measures	Spill cleanup, containment
7	Handling and storage	Safe handling, incompatible materials, storage conditions
8	Exposure controls/personal protection	OSHA PELs, ACGIH TLVs, required PPE
9	Physical and chemical properties	Appearance, odor, flash point, pH, etc.
10	Stability and reactivity	Chemical stability, hazardous decomposition products
11	Toxicological information	Routes of exposure, symptoms, chronic effects
12	Ecological information	Environmental fate (non-mandatory under U.S. law)
13	Disposal considerations	Waste disposal methods (non-mandatory under U.S. law)
14	Transport information	DOT/IATA classification (non-mandatory under U.S. law)
15	Regulatory information	Applicable regulations beyond HazCom
16	Other information	Date of preparation, revision history

Sections 12 through 15 are part of the GHS format but non-mandatory under U.S. law. Manufacturers may leave them blank or mark them not applicable. ^[1] Most reputable manufacturers fill them in anyway.

As an employer, you do not write SDSs. You receive them from suppliers. Your job is to keep them, keep them current, and keep them accessible. If a supplier ships a chemical without an SDS, you have to request one before exposing workers to it. Get the SDS in hand before the chemical goes into use.

What does HazCom employee training actually have to cover?

Training is where small employers have the biggest gaps. The standard at 29 CFR 1910.1200(h) spells out what training must cover, and it's more detailed than most employers expect. ^[1]

Workers must be trained on the requirements of the HazCom standard and any operations in their work area where hazardous chemicals are present; the location and availability of the written program, the SDS file, and the chemical list; the methods and observations used to detect a chemical release (visual cues, odor, monitoring equipment); the physical and health hazards of the chemicals in their area; and the measures they can take to protect themselves, including PPE, work practices, and emergency procedures.

Workers also have to be taught how to read and use SDSs and labels. Handing someone a binder without showing them how to find the exposure limit in Section 8 or the first-aid steps in Section 4 misses the whole point of the standard.

Training does not have to cover every individual chemical. OSHA allows category-based training. A worker can be trained on "corrosive liquids" as a group rather than separately on hydrochloric acid, sulfuric acid, and sodium hydroxide, as long as the hazard information for that category is complete. ^[1] That's real relief for workplaces with big inventories.

There's no required training length, format (classroom, video, computer-based), or test score. What matters is that the training worked and that you can prove it happened. Keep records of who was trained, when, what topics were covered, and who delivered it. Inspectors will ask.

Retraining is triggered when new hazards enter the workplace, not by a calendar. Plenty of employers run annual refreshers anyway, and if your turnover is high, more frequent training just makes sense.

What are the HazCom penalties and how do inspectors cite violations?

HazCom violations almost always fall into four buckets that mirror the standard's four requirements: missing or incomplete written program, missing or inaccessible SDSs, unlabeled or mislabeled containers, and inadequate training records.

As of January 2024, OSHA's civil penalty maxima are $16,131 per serious violation and $161,323 per willful or repeat violation. ^[3] Most first-time HazCom citations for smaller employers land as "other than serious" or "serious" in the $500 to $5,000 range per violation, though that depends heavily on the inspector's read of the severity and your good faith.

Here's the pattern inspectors run. They ask to see your written HazCom program. They ask for your SDS binder covering chemicals in a specific work area. They physically check that the SDSs match what's on the shelf. They look for unlabeled containers. Then they ask workers what to do if they're exposed to a chemical. If a worker can't say where the SDSs are or what the signal words on a label mean, that becomes evidence of inadequate training.

One violation gets missed constantly: the multi-employer worksite provision. Hire a cleaning contractor who brings their own chemicals, have no mechanism to exchange SDSs with them, and you're out of compliance even though you never brought those chemicals in. ^[1]

The informal settlement process is where money gets saved. Most small employers cited for HazCom can negotiate reductions of 25 to 50 percent by showing up to the informal conference with proof the gap is already fixed. Fixing the problem before the conference matters far more than arguing about whether the violation happened.

How does HazCom apply to specific industries like construction, healthcare, and retail?

The standard covers nearly every industry, but the enforcement focus and the practical headaches change by sector.

Construction. Covered under 29 CFR 1926.59, which adopts the general industry rule by reference. Construction sites are multi-employer by nature, so the SDS exchange requirement carries real weight. A concrete sub and a painting sub on the same site each need to know about the other's chemicals. The construction products that generate the most citations: concrete curing compounds, epoxy adhesives, spray foam insulation, and various solvents and coatings.

Healthcare. Hospitals and clinics work with disinfectants, sterilizing agents, anesthetic gases, and chemotherapy drugs, all hazardous chemicals under HazCom. OSHA has a compliance directive for healthcare that addresses how the standard interacts with FDA-regulated drugs. Drugs meant for direct patient administration are generally exempt from HazCom labeling, but the bulk containers they're stored in are not. ^[1]

Retail. Many retail employers assume consumer products are exempt. The consumer product exemption is narrow. It applies only if the product is used the way a consumer would use it, at the same frequency and duration, with exposure no greater than a consumer would experience. A janitorial worker using bleach-based cleaner all day, every day, does not meet that condition even if the product sits on a store shelf. ^[1]

Manufacturing. This is the sector with the most citation exposure. Large chemical inventories, bulk storage, and process operations that throw off hazardous byproducts (welding fumes, machining mists) all fall under HazCom. The SDS requirement reaches chemicals generated in the process, not only chemicals bought from suppliers, though OSHA gives some relief for reaction intermediates contained inside a closed system.

For osha training requirements beyond HazCom, including chemical-specific standards like Respiratory Protection and Bloodborne Pathogens, those layer on top of HazCom rather than replacing it.

What chemicals are exempt from the HazCom standard?

The standard lists exemptions at 29 CFR 1910.1200(b)(6). ^[1] They're narrower than most employers hope.

Exempted categories include hazardous waste subject to the Resource Conservation and Recovery Act (RCRA), tobacco and tobacco products, wood and wood products (in their natural state, though wood dust from processing is not exempt), articles (products that don't release a hazardous chemical under normal use), food and drugs intended for personal consumption, cosmetics for personal consumption, ionizing and non-ionizing radiation, and biological hazards.

The consumer product exemption earns a second mention because employers misread it so often. The text of the standard exempts consumer products only when they are "used in the workplace in the same manner as normal consumer use, and which results in a duration and frequency of exposure which is not greater than exposures experienced by consumers." ^[1] That qualifier wipes out the exemption for most professional or industrial uses of consumer products.

Farm operations with ten or fewer employees that also used no temporary labor in the past year get a partial exemption under the agriculture provisions. ^[5]

Chemicals generated as byproducts of workplace processes, like welding fumes or paint mist, are covered. If your workers' activities create a chemical hazard, that hazard falls under HazCom even if you never bought the substance. So welding fumes require an SDS (or equivalent documentation of the fume composition) and worker training.

How do you build a HazCom program from scratch without a consultant?

Here's the sequence that actually works for a small employer.

Start with a chemical inventory. Walk every work area and list every chemical product present: drums, spray bottles, totes, bags, and any process chemicals. Don't skip the small containers of lubricants, adhesives, or cleaning products. Anything with a manufacturer label reading "Danger" or "Warning" is almost certainly covered.

Get SDSs for everything on that list. Suppliers must provide SDSs on request, usually right off their website or through a quick email to their safety department. Organize the sheets so you can find them by product name in a stressful moment, like a spill or a medical emergency.

Write your program. It doesn't need to be long. A sharp 4-page program that describes your actual workplace satisfies the standard better than a 30-page generic template. Name a responsible person, describe your labeling procedures, state where SDSs are stored, describe your training approach, and outline your multi-employer and non-routine task procedures. That's the core. SafetyFolio's safety program generator builds a tailored written program in about 15 minutes if you want a structured starting point.

Train your workers. Use the SDSs you just organized as the material. Walk workers through a sample SDS and show them where the hazards live, the exposure limits in Section 8, the first-aid steps in Section 4, and the PPE requirements. Confirm they know where the SDS binder or electronic file is. Document who attended, when, and what was covered.

Audit your labels. After training, do a walk-through hunting for unlabeled secondary containers, faded labels, and containers whose product identifier doesn't match an SDS. Fix those before an inspector finds them.

Review and update. When a new chemical arrives, get the SDS before it goes into use. When your inventory shifts a lot, update the written program. When new hazards show up, retrain the affected workers before they're exposed. Run that cycle consistently and you stay compliant without a consultant on retainer.

How does OSHA's HazCom standard interact with other chemical-specific standards?

HazCom is the floor. OSHA also has about 28 substance-specific standards for particularly dangerous chemicals, including lead (29 CFR 1910.1025), asbestos (29 CFR 1910.1001), benzene (29 CFR 1910.1028), and hexavalent chromium (29 CFR 1910.1026). ^[7] Where a specific standard exists, it adds to HazCom rather than replacing it. You comply with both.

Substance-specific standards usually demand more than HazCom does: medical surveillance, biological exposure monitoring, engineering controls to hit specific permissible exposure limits (PELs), and detailed recordkeeping. The lead standard, for one, requires blood lead testing and medical removal protection for workers whose exposure passes the action level. HazCom would require labeling and SDS access but would never, on its own, require blood testing.

Process Safety Management (PSM) at 29 CFR 1910.119 is another overlay. PSM applies to facilities using highly hazardous chemicals above specified threshold quantities, with 10,000 pounds for flammable liquids and gases being one common threshold. ^[8] If PSM applies to you, HazCom is just one layer of a much bigger compliance program.

State Right-to-Know laws pile on more in some places. New Jersey has its own Right to Know Act that covers materials the federal standard doesn't. ^[9] Employers in states with their own OSHA-approved state plans (22 state plans cover private employers as of 2024) have to check whether the state's HazCom standard is at least as effective as the federal rule and whether it adds anything. ^[10]

For a wider look at how OSHA works and which other standards touch your industry, the osha overview on SafetyFolio covers the agency's structure and how its standards are organized.

Frequently asked questions

Does the HazCom standard apply to small businesses with only a few employees?

Yes. There is no employee-count threshold in 29 CFR 1910.1200. If even one worker may be exposed to a hazardous chemical under normal working conditions or in a foreseeable emergency, the standard applies. A five-person auto body shop, a one-employee cleaning service, and a two-person maintenance crew at an apartment complex all fall under HazCom if they use hazardous chemicals.

What is the difference between an SDS and an MSDS?

MSDS stands for Material Safety Data Sheet, the old format used before OSHA aligned with GHS in 2012. SDSs replaced MSDSs and use a mandatory 16-section format. MSDSs had no required structure, so content varied widely between manufacturers. If you still have MSDSs in your files from before 2012, they're outdated. Request current 16-section SDSs from your suppliers.

How often do SDSs need to be updated?

Manufacturers must update an SDS when new significant health or physical hazard information becomes available, and must send the updated version to distributors and employers within three months of learning about it. There's no fixed annual cycle. As an employer, check for updates when you receive a new shipment of a chemical whose SDS differs substantially from the one on file.

Can SDSs be stored electronically, or do you need paper copies?

Electronic storage is allowed under 29 CFR 1910.1200(g)(9), as long as workers can reach the system during their shift in their work area. You need a reliable backup for power outages or computer failures, such as printed SDSs for the most hazardous chemicals. Storing SDSs on a server behind a password only the manager knows does not meet the readily accessible requirement.

What are the GHS pictograms and what does each one mean?

There are nine GHS pictograms. Flame: flammable materials. Flame over circle: oxidizers. Exploding bomb: explosives and reactive chemicals. Skull and crossbones: severe acute toxicity. Corrosion: skin and eye corrosion. Gas cylinder: gases under pressure. Health hazard: carcinogens, reproductive toxins, respiratory sensitizers. Exclamation mark: lesser acute hazards and irritants. Environment: aquatic toxicity (non-mandatory in the U.S.). Each appears in a red diamond border on a compliant label.

Do contractors working in my facility need to follow my HazCom program?

Both parties have duties. You must make your SDSs available to contractor employees who may be exposed to your chemicals, and you must tell contractors what labeling system you use and any precautions they need. Contractors owe you the same for chemicals they bring in. The standard at 29 CFR 1910.1200(e)(2) requires employers on multi-employer worksites to exchange this information before work begins.

Is annual HazCom training required?

No. The standard requires training before initial assignment to work with hazardous chemicals and again when new hazards enter the workplace. There's no mandatory annual retraining cycle. That said, if your workforce turns over often or workers can't demonstrate during an inspection that they know how to find and use SDSs and labels, OSHA may treat that as inadequate training regardless of when you last held a session.

What is the HazCom consumer product exemption and when does it actually apply?

Consumer products are exempt only when used in the same manner, frequency, and duration as a normal consumer would use them at home. A retail employee who uses a store-bought cleaner exactly as a homeowner would, briefly and occasionally, may qualify. A cleaning service employee who uses the same product all day every day does not. The exemption is narrow and frequently misapplied by employers hoping to skip SDS and training requirements.

Does HazCom cover chemicals generated in the workplace, like welding fumes?

Yes. The standard covers hazardous chemicals generated in work operations, not only chemicals bought in containers. Welding fumes, spray paint mist, cutting oil mist, and reaction byproducts all fall under HazCom if they present a health or physical hazard. Employers must document the hazards of workplace-generated chemicals in the written program and train workers accordingly, even without a supplier SDS.

What happens if a supplier ships a chemical without an SDS?

You must request one from the supplier before exposing workers to the chemical. Under 29 CFR 1910.1200(g)(6), chemical manufacturers and importers must provide an SDS with the first shipment and again with the first shipment after an SDS update. If a supplier fails to provide one, OSHA's guidance is to contact the supplier, document your request, and hold off on worker exposure until you have the SDS in hand.

How does the 2024 HazCom revision affect employers who already have a compliant program?

The 2024 final rule updated hazard classifications to match the 7th revised GHS edition, clarified labeling for small containers and bulk shipments, and added a few new physical hazard classes. If you have a compliant 2012-era program, your main tasks are: review incoming SDSs as suppliers update them ahead of the January 2026 manufacturer deadline, update your written program and training to reflect new hazard information by July 19, 2026, and replace any labels that no longer meet the updated format.

Can OSHA fine me for an employee's failure to follow HazCom procedures?

OSHA cites employers, not individual workers. If an employee ignores your labeling procedure or bypasses your SDS system, you can still get a citation if OSHA finds the behavior was predictable or that your training and enforcement were inadequate. Documenting corrective action when you catch employees skipping procedures shows good faith and can cut penalty amounts during the informal settlement process.

Where can I find free SDS resources to build my SDS library?

Several sources are free and reliable. Suppliers are legally required to provide SDSs on request, and many post searchable libraries on their websites. The NIOSH Pocket Guide to Chemical Hazards covers hazard and exposure limit information for common industrial chemicals. The EPA's ChemView and the American Chemical Society's CAS databases help with less common substances. Start with your suppliers, since they carry the exact product SDS you need.

Sources

1. OSHA, 29 CFR 1910.1200 Hazard Communication (full standard text): Core requirements of the HazCom standard: written program, SDSs, labels, training, scope, exemptions, and 16-section SDS format
2. OSHA, Top 10 Most Cited Standards FY2023: HazCom ranked second most cited standard in FY2023 with 2,882 violations
3. OSHA, Penalties page (civil penalty maximums adjusted annually): 2024 OSHA penalty maximums: $16,131 per serious violation, $161,323 per willful or repeat violation
4. OSHA, HazCom 2024 Final Rule overview: 2024 revised final rule effective July 19, 2024; manufacturer compliance deadline January 19, 2026; downstream employer deadline July 19, 2026
5. OSHA, 29 CFR 1928.21 Agriculture HazCom exemption: Farm operations with 10 or fewer employees and no temporary labor have a partial HazCom exemption
6. OSHA, Chemical Hazards and Toxic Substances: Substance-specific standards: OSHA maintains approximately 28 substance-specific standards including lead, asbestos, benzene, and hexavalent chromium
7. OSHA, 29 CFR 1910.119 Process Safety Management standard: PSM threshold quantity for flammable liquids and gases is 10,000 pounds
8. New Jersey Department of Health, NJ Worker and Community Right to Know Act: New Jersey's Right to Know Act adds requirements beyond federal HazCom
9. OSHA, State Plans page: As of 2024, 22 state plan states cover private employers with their own OSHA-approved programs
10. NIOSH, Pocket Guide to Chemical Hazards: NIOSH Pocket Guide provides hazard and exposure limit information for common industrial chemicals