To the point about the hazard communication program

Last updated 2026-07-09

What exactly is a hazard communication program?

A hazard communication program, usually called HazCom or the "Right-to-Know" program, is a documented system that tells your workers which hazardous chemicals they might be exposed to and how to protect themselves. It lives in a written plan, on container labels, and in the Safety Data Sheets (SDSs) you keep on file.

The legal home is 29 CFR 1910.1200, OSHA's Hazard Communication Standard. It matches the United Nations Globally Harmonized System of Classification and Labelling of Chemicals (GHS). OSHA adopted GHS in 2012 and phased it in through 2016 ^[1]. Before GHS, workers dealt with inconsistent chemical labels and data sheets from dozens of countries and manufacturers. Now the format is standard worldwide.

The standard covers general industry, construction, maritime, and agriculture. If you have even one worker who may be exposed to a hazardous chemical, the rule applies to you. There is no small-business exemption.

Three things make up the whole program: a written plan, an SDS for every hazardous chemical on site, and a label on every container. Training ties them together. Miss any one piece and you're open to a citation.

Why does HazCom get cited more than any other OSHA standard?

HazCom has been the top or second most-cited OSHA standard in general industry for more than a decade. In fiscal year 2023, OSHA issued 3,213 HazCom citations, making it the second most-cited standard across all industries ^[2]. In construction, it lands in the top ten most years.

The reason isn't that employers are careless about chemical safety. It's that the paperwork slips. An SDS goes missing when a product changes. A new container arrives and nobody relabels it. Training records from two years ago can't be found. OSHA inspectors know exactly where to look, and these gaps are fast to document.

Penalties for serious violations run up to $16,550 per violation under current OSHA limits ^[3]. Willful or repeat violations go to $165,514 per violation. For a small business with thin margins, one inspection that turns up five or six HazCom violations can become a five-figure problem.

Here's the practical lesson. HazCom citations are almost always preventable. The standard is detailed but not complicated. Most violations come from incomplete recordkeeping, not from genuine ignorance of the hazards.

What chemicals does the standard actually cover?

The standard covers any chemical that is a physical hazard (flammable, explosive, reactive) or a health hazard (toxic, carcinogenic, corrosive, sensitizing) ^[1]. OSHA's definition of "hazardous chemical" is deliberately broad. If a manufacturer determines a substance meets GHS classification criteria, they have to provide an SDS and a GHS-compliant label.

Common examples that surprise small employers:

• Cleaning products (bleach, ammonia-based glass cleaner)
• Paints, stains, and solvents
• Welding fumes and cutting fluids
• Fuels and lubricants
• Pesticides used in facility maintenance
• Battery acid
• Compressed gases

A few things are exempt. Articles (solid manufactured items that don't release chemicals under normal use), food and drugs regulated by FDA when used by employees for personal consumption, and wood or wood products in their natural state. But if you're sanding that wood and making dust, the exemption gets complicated fast.

The standard also has a consumer product exemption for chemicals used the same way, for the same duration, and at the same frequency a normal consumer would use them. A cleaning crew that grabs a spray bottle of glass cleaner once a week probably qualifies. The same crew using that product for hours every day almost certainly doesn't ^[4].

When in doubt, get the SDS and train on it. The cost of over-including a chemical is close to nothing.

What must be in the written hazard communication program?

The written program is the backbone. OSHA lists the required elements at 29 CFR 1910.1200(e) ^[1]. Your document has to address:

1. How you'll keep SDSs and make them available to employees during their shift 2. How you handle hazardous chemicals received without a label or with a bad label 3. How you handle non-routine tasks (one-time maintenance jobs where a worker might meet a chemical they don't normally use) 4. How contractors coming onto your site will learn about the chemicals they might be exposed to 5. A list of all hazardous chemicals present in the workplace

The chemical list doesn't need to be fancy. A spreadsheet with the product name, the manufacturer, and where the SDS is filed does the job. Keep it current. When a product leaves the facility for good, drop it. When a new one shows up, it goes on the list before the first container is opened.

Your written program also has to be available to employees, their representatives, and OSHA on request. "Available" means physically reachable during the workday, not locked in a manager's office. Keep a copy in the break room, at the front desk, or wherever fits your layout.

The program doesn't have to be long. OSHA publishes a model written plan you can adapt ^[4]. Substance beats length every time. A two-page document that actually describes your workplace is worth more than a 20-page generic template that matches nothing you do.

For a faster starting point, SafetyFolio's safety program generator can build a HazCom-specific written plan in about 15 minutes from your answers about your chemicals and workforce.

How do Safety Data Sheets work and where do you keep them?

Safety Data Sheets replaced the old Material Safety Data Sheets (MSDS) under the 2012 GHS update. Every SDS now follows a standard 16-section format ^[1]. The sections always run in the same order, so a worker trained on the format can find the health hazard information or the first aid measures on any SDS without hunting.

The 16 sections in order: identification, hazard identification, composition/information on ingredients, first aid measures, firefighting measures, accidental release measures, handling and storage, exposure controls/personal protection, physical and chemical properties, stability and reactivity, toxicological information, ecological information, disposal considerations, transport information, regulatory information, and other information.

For compliance, sections 1 through 11 and 16 must carry the required information. Sections 12 through 15 sit outside OSHA's jurisdiction (they cover environmental and transport rules) but manufacturers usually include them anyway.

You need an SDS for every hazardous chemical in the workplace. Get them from the manufacturer's website, the distributor, or a chemical management database. OSHA's rule at 29 CFR 1910.1200(g)(6) requires SDSs to be readily accessible to employees during their shifts ^[1]. Paper binders work. Electronic systems work too, as long as employees can reach them without barriers (no password they don't have, no device they'd have to ask permission to use) and you have a backup for power outages.

How long do you keep SDSs? OSHA requires you to keep SDSs for 30 years for any chemical employees were exposed to, or records that identify the substance and say where to get the SDS ^[5]. This matters for occupational illness claims. A worker diagnosed with occupational asthma 15 years from now needs that exposure history.

If a supplier changes a formula and sends an updated SDS, replace the old one but keep a copy of the original with a note of the dates it was in use.

What are the GHS label requirements for containers?

Every container of a hazardous chemical in your workplace must be labeled. GHS requires six specific elements on every primary container label ^[1]:

• Product identifier (the chemical name or trade name)
• Signal word ("Danger" for more severe hazards, "Warning" for less severe)
• Hazard statements (standardized phrases describing the nature of the hazard)
• Precautionary statements (how to handle, store, dispose of, and what to do if exposed)
• Pictograms (the red-bordered GHS symbols, one or more as needed)
• Supplier information (name, address, phone of the manufacturer or importer)

Those labels come from the manufacturer. Your job is to not remove or deface them, and to replace damaged labels fast.

Secondary containers trip up most small businesses. When you pour a chemical from the original into a smaller spray bottle or a bucket, that secondary container needs a label too. OSHA allows some room here: if the secondary container is used right away and stays in the control of the person who filled it, a brief label with at least the product name and the relevant hazard warnings is fine ^[4]. If it's going to sit overnight or get used by someone else, treat it like a primary container.

GHS pictograms are nine red-bordered diamond symbols: flame, flame over circle (oxidizer), exploding bomb, corrosion, skull and crossbones, exclamation mark, health hazard (the person with a starburst on the chest), compressed gas cylinder, and environment. Your workers don't have to memorize all nine, but they should recognize what a skull means and what the health hazard symbol covers. That comes through training.

What HazCom training do employees need?

Training is where the standard gets specific, and where many employers fall short. 29 CFR 1910.1200(h) requires training for employees who may be exposed to hazardous chemicals in their work area ^[1]. The timing rule is strict. Training has to happen before the employee's first assignment to work with a hazardous chemical, not after.

The training has to cover:

• The requirements of the HazCom standard and where to find your written program
• Any operations in the work area where hazardous chemicals are present
• The location and availability of the chemical list and SDSs
• How to detect the presence or release of a hazardous chemical (smell, sight, monitoring)
• The physical and health hazards of the chemicals in the work area
• How employees can protect themselves (PPE, work practices, emergency procedures)
• How to read and use the GHS label elements and the SDS 16-section format

You don't have to train on every chemical one by one. You can train on categories of hazard (flammables, corrosives) and on how to use the SDS system to find chemical-specific information. But the training has to be genuinely specific to your workplace. A generic online video with no link to the chemicals your workers actually handle does not meet the standard.

Do you have to retrain when a new chemical shows up? Yes. 29 CFR 1910.1200(h)(1) requires training before initial exposure ^[1]. Adding a new product to your inventory triggers new or updated training. Adding a product that fits a hazard category you already cover (say, a second solvent when workers already trained on solvents) might not need a full new session, but document your reasoning.

Keep training records. OSHA doesn't fix an exact retention period for HazCom training records, but the practical answer is simple: as long as the employee works for you, plus several years after they leave. If a citation or workers' comp claim comes up, you'll need those records.

For how to structure training across all OSHA-required programs, see our guide on workplace safety training.

How do you handle contractors and multi-employer worksites?

If outside contractors work on your property and might be exposed to your hazardous chemicals, you're required to tell them. 29 CFR 1910.1200(e)(2) says employers who produce, use, or store hazardous chemicals must inform other employers of any hazardous chemicals their workers may be exposed to on your site ^[1].

In practice this means giving the contractor access to your SDSs and telling them the hazards and precautions before they start. A short written notice or a pre-work meeting that covers the relevant chemicals usually does it. Document it.

The flip side is when your employees go to a customer's or general contractor's site. You're entitled to the same information from them. Ask for it. Your workers have the right to know what they're walking into.

On construction sites, this is a constant coordination job. General contractors usually keep a master SDS file for the site and require subcontractors to submit SDSs for any chemicals they bring. That's good practice even when no specific contract clause demands it.

What are the most common HazCom violations and how do you avoid them?

OSHA's inspection data, summarized in the agency's annual reports, points to a steady set of HazCom failures ^[2]. Here's a plain breakdown:

Violation Type	Why It Happens	Fix
No written program or outdated program	Template downloaded, never customized	Update annually, assign an owner
Missing or outdated SDSs	Products change, procurement doesn't notify safety	Require SDS before first shipment
Unlabeled secondary containers	Convenience, habit	Label every secondary container, train on it
Training not done before exposure	New hires start work immediately	Build HazCom into new-hire day one
Training records lost or missing	No consistent filing system	Use a simple dated sign-in sheet, scan it
Chemical list incomplete	Never updated after initial setup	Assign quarterly review to a named person
SDSs inaccessible during shift	Locked office, digital system with barriers	Physical binder in work area as backup

The single most effective prevention is giving one person ownership of the program. Not a committee. One named person who checks the chemical list quarterly, makes sure new SDSs arrive before new products do, and keeps the training documentation straight. That person doesn't have to be a safety professional. They just need clear responsibility and a calendar reminder.

Does HazCom apply differently in construction vs. general industry?

The construction HazCom standard sits at 29 CFR 1926.59, but it simply incorporates 29 CFR 1910.1200 by reference ^[6]. The requirements are the same. The practical differences come from how construction sites run: chemicals change job to job, workers from multiple employers share the same space, and there's often no permanent workplace where you can post a binder.

Construction employers have to make SDSs available at the job site. A binder in the job trailer works. A tablet with a chemical management app works if workers can reach it. The multi-employer coordination rules matter more in construction because of how many subs share a typical site.

OSHA's construction HazCom citation count runs lower than general industry in raw numbers, mostly because construction inspections lean hard on fall protection and excavation safety. But HazCom still turns up regularly when inspectors look at confined spaces, roofing operations, painting, and demolition work where chemicals are front and center.

How do state OSHA plans affect your HazCom requirements?

Twenty-two states and two territories run their own OSHA-approved plans for private employers ^[7]. State plans have to be "at least as effective" as federal OSHA, and most adopted the federal HazCom standard directly or with minor additions.

California is the one to watch. Cal/OSHA has its own Hazard Communication Regulation (Title 8, CCR Section 5194) plus an added requirement under the California Hazardous Substances Information and Training Act (Labor Code Sections 6360-6399.7) ^[8]. California employers also deal with Proposition 65, which requires warnings for exposures to listed carcinogens and reproductive toxins. Prop 65 is not an OSHA standard, but it interacts with HazCom in ways that catch small employers off guard.

If you're in a state-plan state, check your state's specific HazCom rules with the state agency. The requirements are usually identical to federal OSHA, but penalty structures and inspection priorities can differ.

For a broader look at how program requirements differ between state-plan and federal coverage, the SafetyFolio guide on a safety and health program should be covers the framework.

How do you build or update a HazCom program from scratch?

Starting from zero? Here's the practical sequence.

Step 1: Inventory your chemicals. Walk the facility. Open every cabinet, storage room, and maintenance closet. List every product that could be a hazardous chemical. Include the stuff under the sink and the aerosol cans in the supply room. This list becomes Section 1 of your written program.

Step 2: Get an SDS for everything on the list. Go to each manufacturer's website. Most post SDSs publicly. Download and save them in a consistent file-naming format (manufacturer-productname-version-date works well). Print the SDS for any chemical where workers don't have reliable computer access during their shift.

Step 3: Check every container label. Any container without a legible GHS-compliant label needs one. Contact the manufacturer for a replacement label if the original is damaged.

Step 4: Write the program. Use OSHA's model plan as a starting point ^[4]. Fill in the specifics: your company name, who is responsible, where the SDSs live, how you handle new chemicals, how you handle non-routine tasks. Don't copy boilerplate and call it done.

Step 5: Train employees. Before they work with any hazardous chemical. Document the training with names, dates, and topics covered.

Step 6: Set a calendar reminder for quarterly reviews. New chemicals added, old ones removed, SDSs updated, training records current. Fifteen minutes a quarter keeps the program alive.

The whole process for a small business with 20 to 30 chemicals might take six to eight hours the first time. After that, it's a maintenance task.

What records do you need and how long do you keep them?

HazCom has two main recordkeeping threads: the SDSs themselves and the training records.

For SDSs: OSHA requires you to keep records of employee exposure to hazardous chemicals for 30 years, or keep the SDS itself for that period ^[5]. The 30-year rule comes from 29 CFR 1910.1020, the Access to Employee Exposure and Medical Records standard. If a product is no longer in the building, you don't need the current SDS, but you need either the old SDS or a record that lets you identify the substance and find exposure information.

For training records: OSHA's HazCom standard sets no specific retention period for training documentation. The practical standard most compliance professionals apply is the duration of employment plus three years. If a worker files a workers' comp or occupational illness claim years after leaving, you want proof they were trained.

For the written program: keep the current version and prior versions with dates. If OSHA asks when you updated the program, you need to show the history.

All of this can live in a simple filing system. A physical binder for SDSs, a spreadsheet tracking who was trained on what date, and a folder of dated program versions. You don't need software. You do need consistency.

For broader recordkeeping obligations under OSHA, the hazardous communication guide on this site covers the overlap with 29 CFR 1904 injury recordkeeping.

Frequently asked questions

Is a written hazard communication program required for every business?

Yes, if any employee may be exposed to a hazardous chemical. There is no size exemption in 29 CFR 1910.1200. A one-person shop that uses cleaning chemicals still needs a written program. The scope covers general industry, construction, maritime, and agriculture. The only fully exempt workplaces are those with no hazardous chemicals present at all, which is rare.

What is the difference between an SDS and an MSDS?

Material Safety Data Sheets (MSDS) were the predecessor format. OSHA's 2012 GHS update replaced MSDS with Safety Data Sheets (SDS) in a standard 16-section format. The content is similar but the new format is consistent across all manufacturers and countries. OSHA required full compliance with the SDS format by June 1, 2016.

Can I keep SDSs electronically instead of in a paper binder?

Yes. Electronic SDS systems are acceptable under 29 CFR 1910.1200(g)(8) as long as employees can reach them immediately during their shift without barriers. OSHA's position is that you also need a backup for electronic failures, such as a contact number for chemical information or a paper backup for the most-used chemicals. Power outages are the main scenario to plan for.

Do I need to train employees every year on HazCom?

OSHA does not require annual retraining. Training is required before initial exposure and when a new physical or health hazard enters the work area. Many employers run annual refreshers anyway as good practice and to document that workers still know the program. If you introduce a new chemical with a hazard category not previously covered, retraining on that hazard is required.

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

You can't use the chemical until you have an SDS. Request one from the supplier immediately. 29 CFR 1910.1200(g)(6) requires SDSs to be available before employee exposure. If the supplier can't provide one, contact OSHA's technical staff or the chemical manufacturer directly. Using an unidentified hazardous chemical without an SDS is itself a violation.

How do I handle homemade or mixed chemicals in my workplace?

If you mix chemicals to create a new substance used in your own workplace, you are the employer who produces that chemical under the standard. You must determine if it is hazardous, create an SDS for it, and label containers. If you sell or transfer it to another employer, you take on manufacturer obligations. Mixing chemicals without evaluating the new hazards is a serious compliance gap.

Does HazCom cover compressed gases like propane and oxygen cylinders?

Yes. Compressed gases are specifically addressed in GHS classification and require labels and SDSs. The compressed gas cylinder pictogram is one of the nine GHS symbols. Workers using propane torches, welding gases, or compressed oxygen need training on the specific hazards: asphyxiation risk, pressure hazards, and flammability. The cylinder itself is the primary container and must carry a compliant label.

What is the fine for a HazCom violation?

As of 2024, OSHA's penalty for a serious HazCom violation is up to $16,550 per violation. Willful or repeat violations can reach $165,514 per violation. OSHA adjusts these figures annually based on the Consumer Price Index. Small employers may get penalty reductions based on size (up to 70% for employers with 25 or fewer employees) and good faith efforts to comply.

Do temporary or seasonal employees need HazCom training?

Yes. The standard covers all employees who may be exposed to hazardous chemicals, with no exception for temporary, part-time, or seasonal status. OSHA has issued letters of interpretation clarifying that staffing agency employees must be trained before starting work involving chemical exposure. Either the host employer or the staffing agency can provide the training, but it has to happen before first exposure.

What does a HazCom inspection typically look like?

An OSHA compliance officer usually asks to see your written program, your chemical list, and your SDS file, then verifies that the chemicals on site match the list. They'll check container labels for GHS compliance. They may interview employees to test training, asking workers to find an SDS or identify a pictogram. Inspections often open with a record review, so organized documents matter.

Can I use a generic HazCom program template I found online?

You can use a template as a starting point, but it has to be customized to your actual workplace to be compliant. OSHA's inspection guidance looks for programs that reflect the employer's specific chemicals, operations, and layout. A template that refers to "chemical storage room B" when your facility has no such room, or lists procedures that don't match your work, is a liability, not a protection.

How does the GHS affect international shipments and chemicals from other countries?

Importers of hazardous chemicals are treated as manufacturers under the HazCom standard. They are responsible for ensuring GHS-compliant labels and SDSs accompany any chemical imported into the US. If you receive an imported chemical with a foreign-format label or SDS, the importer has not met their obligations. Don't expose workers to that chemical until compliant documentation is in hand.

Sources

1. OSHA, 29 CFR 1910.1200 Hazard Communication Standard (full regulatory text): The standard requires written programs, SDSs in the 16-section GHS format, GHS-compliant labels with six elements, and employee training before initial exposure to hazardous chemicals.
2. OSHA, Top 10 Most Frequently Cited Standards FY 2023: Hazard Communication was the second most-cited OSHA standard in FY2023 with 3,213 citations.
3. OSHA, Penalties page: Serious violations carry penalties up to $16,550 per violation; willful or repeat violations up to $165,514 per violation.
4. OSHA, Hazard Communication Safety and Health Topics page and model written plan: OSHA publishes a model written hazard communication program and guidance on the consumer product exemption for chemicals used in the same manner as a typical consumer.
5. OSHA, 29 CFR 1910.1020 Access to Employee Exposure and Medical Records: Employers must preserve and maintain employee exposure records, including SDSs for chemicals to which employees were exposed, for at least 30 years.
6. OSHA, 29 CFR 1926.59 Hazard Communication (Construction): The construction HazCom standard at 29 CFR 1926.59 incorporates 29 CFR 1910.1200 by reference, making the requirements identical for construction employers.
7. OSHA, State Plans page: Twenty-two states and two territories operate OSHA-approved state plans covering private employers; state plans must be at least as effective as federal OSHA.
8. United Nations Economic Commission for Europe, Globally Harmonized System of Classification and Labelling of Chemicals (GHS) overview: The GHS standardizes chemical hazard classification and communication worldwide; OSHA matched the HazCom standard to GHS in 2012.
9. OSHA, Letters of Interpretation: Hazard Communication, temporary employees: OSHA letters of interpretation clarify that temporary and staffing agency employees must receive HazCom training before exposure, and that responsibility may rest with either the host or agency employer.