Hazard Communication Program Guide

A hazard communication program is a written plan that explains how your workplace identifies, labels and communicates information about hazardous chemicals to workers. Required by OSHA's Hazard Communication Standard (HCS) under 29 CFR 1910.1200, the HazCom program ensures that every employee who may be exposed to hazardous chemicals knows what those chemicals are, what risks they pose and how to work with them safely. HazCom consistently ranks among OSHA's top ten most-cited standards, which means inspectors look for it specifically - and find violations regularly.

Who Needs a Hazard Communication Program

If your workplace uses, stores or produces any hazardous chemicals, you need a written HazCom program. This applies far more broadly than many employers realize. "Hazardous chemicals" does not just mean industrial solvents and acids. The definition includes:

• Cleaning products (degreasers, disinfectants, floor strippers)
• Paints, coatings and adhesives
• Welding rod coatings and fumes
• Fuels and lubricants
• Concrete admixtures and curing compounds
• Pesticides and herbicides
• Laboratory chemicals
• Manufacturing process chemicals

If your workers come into contact with any chemical beyond consumer-use quantities and conditions, you need a program. The only exemptions are narrowly defined: consumer products used in the same manner and frequency as a normal household, articles that do not release hazardous chemicals under normal use and a few other specific categories.

The Four Pillars of a HazCom Program

OSHA's Hazard Communication Standard rests on four requirements. Your written program must address each one and describe how your workplace implements it.

1. Written Hazard Communication Program

The written plan is the backbone of your HazCom compliance. It does not need to be long, but it must be specific to your workplace - not a generic template downloaded from the internet. OSHA expects the plan to describe:

• How your workplace meets each element of the HCS
• Who is responsible for each element (specific names or job titles)
• A current list of all hazardous chemicals present in the workplace
• How safety data sheets are obtained, maintained and made accessible
• How container labeling is managed
• How worker training is conducted and documented
• How the program addresses non-routine tasks and unlabeled pipes
• How information is shared with contractors and other employers on multi-employer worksites

The written program must be available to any employee upon request. Store it in a known, accessible location - ideally both in a physical binder and on a digital platform like Make Safety Easy's Document Management system where any authorized worker can access it from any device.

2. Safety Data Sheets (SDS)

Safety data sheets are the primary technical resource for chemical hazard information. Under the Globally Harmonized System (GHS), every SDS follows a standardized 16-section format that covers identification, hazards, composition, first aid, fire-fighting measures, handling, exposure controls, physical properties, stability, toxicology, ecology, disposal, transport, regulatory information and other details.

Your responsibilities as an employer:

• Obtain an SDS for every hazardous chemical - The chemical manufacturer or distributor must provide one with the initial shipment. If you do not receive it, request it in writing.
• Maintain a current SDS file - Keep SDSs for every chemical currently on site. When a product is replaced with a newer formulation, update the SDS.
• Make SDSs readily accessible - Workers must be able to access SDSs during their shifts without asking permission or searching through locked cabinets. Electronic access is acceptable as long as workers know how to use the system and can access it without barriers.
• Train workers on SDS interpretation - An SDS is useless if workers cannot read and understand it. Training must cover the 16-section format and how to find critical information like exposure limits, first aid procedures and required PPE.

For a deeper look at managing safety data sheets effectively, see our complete SDS guide.

3. Labels and Warnings

Container labeling is the first line of hazard communication. Workers encounter labels far more often than they consult SDSs, which makes proper labeling one of the most practical safety measures in any chemical workplace.

Manufacturer Labels

Under GHS, chemical manufacturers must include six elements on every shipped container:

• Product identifier - The chemical name or product name matching the SDS
• Signal word - Either "Danger" (more severe hazards) or "Warning" (less severe)
• Hazard statements - Standardized phrases describing the nature and degree of hazard
• Pictograms - Red-bordered diamond symbols indicating hazard categories (flame, skull, exclamation mark, etc.)
• Precautionary statements - Recommended measures to minimize exposure or harmful effects
• Supplier identification - Name, address and phone number of the manufacturer, importer or distributor

Never remove or deface a manufacturer's label on a chemical container that still holds its original contents.

Workplace Labels

When chemicals are transferred from the original container to a secondary container for use, the secondary container must be labeled with at least the product identity and the words, pictures or symbols that convey the hazards. The only exception is a portable container intended for immediate use by the worker who filled it - and "immediate" means within the same shift.

Unlabeled secondary containers are one of the most common HazCom citations OSHA issues. Prevent this by keeping pre-printed workplace labels available wherever chemicals are transferred and training workers that every container must be labeled before it leaves their hands.

4. Worker Training

Training is where the HazCom program comes to life. Workers who cannot identify hazardous chemicals, interpret labels and use SDSs are unprotected regardless of how thorough your written program is.

OSHA requires HazCom training at two points: when a worker is initially assigned to a work area containing hazardous chemicals and when a new chemical hazard is introduced. Training must cover:

• The requirements of the Hazard Communication Standard
• The location and availability of the written HazCom program and SDS file
• The physical and health hazards of chemicals in the work area
• How to detect the presence or release of hazardous chemicals (visual appearance, odor, monitoring equipment)
• Protective measures - engineering controls, work practices, PPE and emergency procedures
• How to read and interpret labels and SDSs

Training does not need to cover every chemical individually. You can train by hazard category - "all flammable liquids in this area require these precautions" - as long as workers can apply the training to specific products they encounter.

Building Your Chemical Inventory

The chemical inventory is the master list of every hazardous chemical present in your workplace. It is the foundation of your HazCom program because it determines which SDSs you need, which training topics to cover and which areas of your facility require chemical-specific controls.

To build a comprehensive inventory:

• Walk every area - Check production floors, maintenance shops, janitorial closets, loading docks, storage rooms and offices. Chemicals hide in places you do not expect.
• Check purchasing records - Cross-reference what you find on site with what your purchasing department has ordered. This catches chemicals that may be stored offsite or in transit.
• Include process byproducts - Welding fumes, wood dust, silica dust from concrete cutting and similar byproducts of work processes are hazardous chemicals under the HCS and must be included.
• Update regularly - New products arrive, old ones are discontinued and formulations change. Review and update the inventory at least quarterly.

Multi-Employer Worksite Requirements

Construction sites, manufacturing plants with contractors and any workplace where employees of different companies work in the same area trigger additional HazCom obligations. When your workers are exposed to chemicals brought on site by another employer, you must:

• Obtain SDSs from the other employer for chemicals your workers may be exposed to
• Inform the other employer about the chemicals your operations produce or use that their workers may encounter
• Make SDSs from all employers available to all affected workers
• Coordinate labeling systems so workers from any employer can identify hazards

Include specific procedures for contractor communication in your written HazCom program. Do not assume contractors will manage their own hazard communication independently - verify it.

Common HazCom Program Deficiencies

After decades of enforcement, OSHA inspectors know exactly where HazCom programs fail. Avoid these frequent deficiencies:

• Generic written plan - A boilerplate document that does not reflect your specific workplace, chemicals or procedures will not survive an inspection.
• Incomplete chemical inventory - Missing chemicals mean missing SDSs, missing training and missing protection.
• Outdated SDSs - If you switched to a new product formulation but still have the old SDS on file, your workers have inaccurate hazard information.
• No training documentation - Training that is not documented did not happen as far as OSHA is concerned. Keep signed attendance records with topics covered and dates.
• Inaccessible SDSs - A binder locked in a supervisor's office does not meet the accessibility standard. Workers must be able to reach SDSs during their shifts without delay.
• Unlabeled secondary containers - This remains one of the most cited violations year after year. Make workplace labeling a mandatory step in every chemical transfer.

Keeping Your HazCom Program Current

A HazCom program is not a one-time project. It requires ongoing maintenance to remain compliant and effective.

• Annual review - At minimum, review the entire written program once per year. Update the chemical inventory, verify SDS accuracy and confirm that training records are complete.
• New chemical introduction - Every time a new hazardous chemical enters the workplace, obtain the SDS before the chemical arrives, update the inventory, update labeling procedures and train affected workers before they use the product.
• Regulatory changes - OSHA periodically updates the HCS. Most recently, the 2024 update to 29 CFR 1910.1200 revised GHS alignment provisions. Monitor regulatory changes and update your program accordingly.
• Incident-driven updates - If a chemical exposure incident occurs, review whether the HazCom program adequately addressed the hazard and make improvements.

Get Your HazCom Program Organized

Managing a hazard communication program across an entire organization - multiple sites, hundreds of chemicals, thousands of SDSs and ongoing training requirements - is a massive administrative challenge on paper. Digital document management transforms it from a burden into a system that runs itself.

Make Safety Easy's Document Management feature stores your written HazCom plan, SDS library and training records in one searchable platform accessible to every worker. Updates propagate instantly across all locations and automated reminders ensure nothing falls through the cracks. Schedule a demo to see the platform in action, or check our pricing page to find a plan that fits your operation.