OSHA's Hazard Communication Standard requires a written program, chemical inventory, SDS for every hazardous chemical, proper labeling, and employee training. Here's what each requirement actually means.
OSHA's Hazard Communication Standard (HazCom), codified at 29 CFR 1910.1200, is one of the most frequently cited OSHA standards year after year — and one of the most misunderstood. The regulation applies to virtually every employer that uses chemicals in the workplace, from a janitorial closet with bleach and floor stripper to a chemical plant with hundreds of substances. This guide breaks down every component of a compliant HAZCOM program, explains what changed when OSHA aligned with the Globally Harmonized System (GHS), and tells you exactly what your employees need to know.
HAZCOM is OSHA's framework for ensuring that employers and employees know the identities and hazards of the chemicals they work with. The core principle is simple: workers have a right to know what they're being exposed to and how to protect themselves. The regulation creates that right-to-know by requiring employers to maintain information (Safety Data Sheets), communicate hazards through labels, and train workers to use both.
HazCom 2012 — the current version — aligned OSHA's standard with the Globally Harmonized System of Classification and Labelling of Chemicals (GHS), a United Nations framework that standardizes how chemical hazards are classified and communicated worldwide. The alignment was finalized in 2012; most employers were required to be fully compliant by June 1, 2016. The key practical changes from the old HazCom standard: Material Safety Data Sheets (MSDSs) became Safety Data Sheets (SDSs) with a mandatory 16-section format, and labels acquired standardized pictograms and signal words.
A compliant HAZCOM program requires five distinct elements. If any one of them is missing, you are in violation — even if the other four are perfect.
You must have a written document describing how your facility implements HazCom. It does not need to be long, but it must address: how you maintain your chemical inventory, how SDSs are obtained and kept current, how containers are labeled, and how employees are trained. The written program must also identify the person responsible for each function. OSHA compliance officers ask to see the written program first. If it doesn't exist, the inspection goes downhill from there.
Maintain a list of every hazardous chemical present in your workplace. "Hazardous chemical" under HazCom means any chemical that is a physical hazard (flammable, explosive, oxidizer, compressed gas, reactive) or a health hazard (toxic, carcinogen, irritant, sensitizer, corrosive). The inventory should list the product name as it appears on the SDS, the location where it's used or stored, and the SDS document reference. Consumer products used in the quantities and frequency a normal consumer would use them are generally exempt, but anything purchased in bulk or used repeatedly by workers is not.
You must have an SDS for every hazardous chemical on your inventory. SDSs must be readily accessible to employees during their work shift — not locked in the safety manager's office, not on a computer system that requires a password no one knows, and not in a binder stored in a building the employee doesn't work in. Accessibility is not a technicality. It is a core requirement that directly enables a worker to get critical information during an emergency.
Under GHS-aligned HazCom 2012, every SDS must follow a standardized 16-section format. The sections are, in order:
Sections 1 through 11 are the sections employees and emergency responders use most. Section 8 is critical for PPE selection — it tells you exactly what protection is required for routine handling. Section 4 is what your first aid responders need during an exposure incident. Know where to find these sections quickly; that knowledge is as important as having the binder.
Every container of a hazardous chemical in your workplace must be labeled. Manufacturer-applied labels on original containers satisfy this requirement as long as the label is legible and intact. Secondary containers — any container you fill from the original, including spray bottles, portable tanks, or process vessels — must also be labeled. OSHA allows abbreviated labels for secondary containers used within a single shift by the person who filled them, but any container that could be used by someone other than the person who filled it needs a proper label.
Under GHS-aligned HazCom, a compliant label must include six elements:
The nine GHS pictograms cover: health hazard (exclamation mark), serious health hazard (person with starburst), flame, flame over circle (oxidizer), gas cylinder, corrosion, skull and crossbones, exploding bomb, and environment (dead tree and fish). Your employees should be able to recognize all nine — and understand what each one means for their protection.
Training must be provided at initial assignment and whenever a new chemical hazard is introduced to the work area. OSHA does not specify a minimum number of training hours, but the training must cover:
Document every training session. Records should show the date, the topics covered, and the names of employees who attended. A sign-in sheet is the minimum. A brief written or electronic quiz adds defensibility during an audit.
Before HazCom 2012, chemical safety information was communicated through Material Safety Data Sheets (MSDSs). MSDSs had no required format — section order, content depth, and layout varied widely by manufacturer. A worker trying to find first-aid information on a product from one manufacturer might find it on page 1; on a product from another manufacturer, it might be buried on page 4 under a different heading. The GHS-aligned SDS fixes this with the mandatory 16-section sequence. Section 4 is always first-aid measures, on every SDS, from every manufacturer. That standardization has real consequences for emergency response speed.
If you still have MSDSs in your binder from before 2016, they are out of compliance. Contact the chemical manufacturer and request current GHS-format SDSs, or use a commercial SDS management service that maintains updated documents automatically.
HazCom applies to construction under 29 CFR 1926.59, which incorporates 1910.1200 by reference. Construction employers must maintain SDS access at the job site, train workers on chemicals present on that specific project, and ensure containers are labeled. Multi-employer construction sites create additional complexity: the controlling contractor is generally responsible for ensuring that all subcontractors comply with HazCom, and that SDSs from all employers' chemicals are accessible to all workers who might encounter them. If you are a subcontractor, you are responsible for your own chemicals — and your own training records.
Aaron West
Founder, EHS, Inc. — 18+ years in EHS compliance and contractor safety
Aaron West has spent over 18 years helping contractors and businesses navigate OSHA compliance, ISNetworld® certification, and workplace safety management. He founded EHS, Inc. to make enterprise-level EHS accessible to companies of all sizes — serving contractors and businesses nationwide — without long-term contracts or enterprise overhead.
Our team handles the complexity so you can focus on running your business. No long-term contracts, no learning curve.
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