Introduction to OSHA Hazard Communication Standard (HazCom)
The OSHA Hazard Communication Standard (29 CFR 1910.1200) ensures employees’ right to know and understand the hazards associated with chemicals in their workplace. This standard applies to nearly all industries—including manufacturers, importers, distributors, and employers who use hazardous chemicals—and aligns U.S. requirements with the Globally Harmonized System (GHS). The GHS framework standardizes labels, pictograms, and Safety Data Sheets (SDS) to enhance communication and workplace safety across industries.
An effective HazCom program includes:
- A written plan describing labeling, SDS access, employee training, and communication methods for non-routine tasks and contractors.
- A current chemical inventory reflecting onsite chemicals, including maintenance and process materials, as well as consumer products used beyond typical consumer exposure.
- Labeling for all containers—including workplace or secondary containers—showing product identifiers, hazard information, and GHS elements where applicable.
- Accessible SDS management ensuring 16-section Safety Data Sheets are readily available to employees each shift, with proper version control and prompt updates.
- Chemical safety training at initial assignment and whenever new hazards are introduced, delivered in a format and language workers understand.
GHS alignment requires consistent hazard classification and label components: signal words (“Danger” or “Warning”), standardized hazard statements, pictograms (e.g., flame, corrosive, health hazard), and precautionary statements. For example, if a maintenance team transfers a flammable solvent into spray bottles, those containers must be labeled and workers must be trained in fire hazards, PPE, and safe handling procedures.
The written program should also address:
- Non-routine tasks (e.g., tank cleaning) and hazards from unlabeled pipes.
- Communication procedures on multi-employer worksites to share hazard information.
- Processes for introducing new chemicals, requesting SDSs, and replacing outdated sheets.
- Emergency preparedness, including spill response and first-aid references.
Common OSHA citations involve missing or outdated SDSs, unlabeled containers, incomplete inventories, or generic training that fails to address workplace-specific hazards. Periodic audits, standardized labels, and role-based training help maintain compliance and employee safety.
National Safety Compliance offers a variety of courses to help businesses maintain Hazard Communication compliance.
Understanding the Employee Right to Know
OSHA Hazard Communication upholds the employee right to know—and understand—the chemical hazards they may encounter. Under 29 CFR 1910.1200, employers must establish a consistent system for hazard identification, communication, and control aligned with GHS principles.
Key compliance elements include:
- Written program: Define roles, chemical inventory, contractor coordination, and hazard control for non-routine tasks.
- Chemical inventory: Maintain a current list linking each chemical to its SDS.
- Labeling: Ensure shipped containers display GHS-aligned labels with product identifiers, signal words, hazard and precautionary statements, pictograms, and supplier details. Label secondary containers as well, unless for immediate use by the person who filled them.
- SDS management: Keep a 16-section SDS for each chemical accessible without barrier—whether paper or electronic. Digital systems must be available during emergencies and easily navigable by workers.
- Training: Conduct chemical safety training at initial assignment and when new hazards appear, in clear language suited to employee understanding.
For example:
- Decanting solvent into spray bottles requires hazard labeling consistent with the SDS.
- Employers and contractors must exchange SDS and label information on multi-employer sites.
- Trade-secret ingredients are permissible, but health and safety details must remain fully disclosed for worker protection.
Routine inventory checks, accurate SDS alignment, and timely updates transform the employee right to know into an effective defense against chemical hazards and OSHA citations.
Core Elements of a HazCom Program
A successful HazCom program is dynamic—embedding OSHA and GHS requirements into daily operations. Each element should be clearly defined, consistently applied, and reviewed periodically for effectiveness.
- Written program: Define responsibilities, SDS and labeling procedures, and training frequency. Include program checkpoints and administrator contact details.
- Chemical inventory: Maintain a real-time list synchronized with current SDSs, covering all production and maintenance chemicals.
- Labeling: Follow GHS workplace labeling—ensure manufacturer labels remain attached and secondary containers display consistent hazard details.
- SDS management: Store the latest 16-section sheets, with backups for network interruptions. Remove superseded versions promptly.
- Training: Deliver bilingual or literacy-appropriate training explaining label elements, SDS use, protective controls, and emergency procedures.
- Non-routine tasks: Plan and communicate hazards before performing uncommon tasks.
- Contractor coordination: Exchange SDSs and hazard communications before work starts.
- PPE and controls: Match each hazard class to proper engineering controls and protective gear.
- Verification: Conduct regular audits and fix compliance issues immediately.
Resources such as pre-printed GHS labels, SDS binders, and comprehensive training aids simplify program upkeep and OSHA compliance.
Safety Data Sheets: The Core of Compliance
Safety Data Sheets (SDS) serve as the central communication tool in OSHA Hazard Communication. Every hazardous chemical must have a readily accessible, current SDS. Forms can be maintained on paper or electronically if access is barrier-free during each shift.
Under the GHS, each SDS must include 16 sections. OSHA enforces the content of Sections 1–11 and 16. Sections 12–15 are voluntary, included for GHS alignment. Workers should pay special attention to Sections 2 (Hazards), 4 (First Aid), 7 (Handling), 8 (Exposure Controls/PPE), and 10 (Stability/Reactivity).
Compliance best practices:
- Link each chemical to its SDS and primary work area.
- Assign staff to verify and replace SDS upon supplier updates.
- Retain older SDS or exposure records for 30 years as required by OSHA (29 CFR 1910.1020).
- Ensure all employees—including remote or temporary workers—can access SDS without delay.
- Conduct annual reviews and whenever new products are introduced.
Incorporate SDS navigation into chemical safety training. Short drills or safety quizzes strengthen retention and reinforce safe practices.
Proper Labeling and Hazard Warnings
Labels are the first line of defense in hazard communication. OSHA requires standardized GHS label elements to ensure chemicals are easily identified and understood at a glance.
Each shipped container label must include:
- Product identifier (matching SDS)
- Signal word: “Danger” or “Warning”
- Hazard statement(s)
- Appropriate pictogram(s)
- Precautionary statements (prevention, response, storage, disposal)
- Supplier contact information
Employers are responsible for workplace (secondary) container labels. Acceptable systems include GHS, NFPA, or HMIS, provided they align with hazard information on the SDS. Portable containers used immediately by one employee do not require labels.
Keep labels synchronized with SDS Section 2 data, update them upon receiving new hazard information, and train employees on all label elements and pictogram meanings.
Effective Employee Training Requirements
Under 29 CFR 1910.1200, employers must provide chemical safety training that is effective, understandable, and relevant. Training should occur at new hire orientation and whenever a new chemical or hazard is introduced.
At minimum, training must cover:
- Written HazCom program overview
- Label reading and interpretation
- SDS access and navigation
- Hazard recognition and exposure prevention
- Protective measures and emergency procedures
- Non-routine task communication
- Multi-employer site coordination
- Employee rights to hazard and exposure information
Document all training sessions—include date, content, attendance, and trainer credentials. Routine refreshers and toolbox talks reinforce retention and compliance.
Employer Compliance Responsibilities
Employers must maintain a written OSHA-compliant program customized for their operations. It should include chemical inventory, labeling protocols, SDS accessibility, training schedules, and communication procedures for contractors and non-routine tasks.
Labels must meet GHS requirements, and SDSs must be readily accessible on every shift. Outdated SDSs should be replaced promptly, and exposure records maintained for 30 years per OSHA rules.
Proactive communication, periodic internal audits, and consistent documentation will demonstrate compliance during OSHA inspections.
Benefits of a Strong Hazard Communication Program
Implementing a robust HazCom program reduces incidents, improves GHS workplace safety, and supports regulatory readiness. Benefits include:
- Reduced injuries and exposures
- Consistent PPE and storage standards
- Improved chemical substitution and reduced environmental risk
- Streamlined audits and lower compliance costs
- Stronger employee confidence and participation
Maintaining Long-Term Compliance
Sustaining OSHA Hazard Communication requires continuous attention: ownership, inspections, updates, and employee involvement. Use KPIs and audit checklists to verify all elements are current and effective. Consistent management ensures your program remains accurate, accessible, and fully compliant 365 days a year.