Setting Up a Hazard Communication Program for Your Workplace

What OSHA Requires

OSHA's Hazard Communication Standard (HCS), found at 29 CFR 1910.1200, requires employers to inform employees about the hazardous chemicals they may be exposed to in the workplace. The standard is built on the principle that employees have a right to know what chemical hazards are present and how to protect themselves.

The HCS applies to any workplace where employees may be exposed to hazardous chemicals under normal conditions of use or in a foreseeable emergency. This covers far more workplaces than most employers realize — cleaning products, paints, adhesives, solvents, fuels, and many other common substances are covered.

The Four Core Requirements

1. Written Hazard Communication Program

You must develop and maintain a written hazard communication program that describes how your workplace will comply with the standard. The program must include:

• A list of all hazardous chemicals present in the workplace
• The methods you will use to inform employees about hazards (labeling, safety data sheets, training)
• How you will inform employees about hazards associated with non-routine tasks
• How you will inform contractors about hazardous chemicals their employees may encounter at your facility

The written program does not need to be elaborate. For a small workplace with few hazardous chemicals, it may be just a few pages. The key is that it accurately describes your procedures.

2. Safety Data Sheets (SDS)

You must maintain a safety data sheet for every hazardous chemical in the workplace. SDSs are provided by the chemical manufacturer or distributor and contain detailed information about the chemical's properties, hazards, safe handling and storage procedures, emergency measures, and exposure controls.

SDSs must follow the standardized 16-section format aligned with the Globally Harmonized System (GHS). The sections cover identification, hazard identification, composition, first-aid measures, fire-fighting measures, accidental release, handling and storage, exposure controls, physical and chemical properties, stability and reactivity, toxicological information, ecological information, disposal considerations, transport information, regulatory information, and other information.

Make SDSs accessible. Employees must be able to access SDSs during their work shifts. This can be through physical binders in work areas, electronic access through a computer or tablet, or a combination. If you use electronic access, ensure employees can retrieve SDSs quickly and that the system is available even during power outages or computer failures.

3. Container Labeling

All containers of hazardous chemicals in the workplace must be labeled. Incoming containers from manufacturers must bear GHS-compliant labels that include:

• Product identifier (chemical name)
• Signal word (Danger or Warning)
• Hazard statements
• Pictograms
• Precautionary statements
• Supplier identification

For secondary containers — when an employee transfers a chemical from its original container to a smaller container for use — labeling is also required unless the employee will use the entire contents during the work shift and the container remains in the employee's possession.

Many employers use simplified workplace labels on secondary containers that include the product name and the key hazards. This is acceptable as long as employees have been trained and can access the full SDS.

4. Employee Training

You must train employees on hazardous chemicals at two points:

Initial training when the employee is first assigned to a work area where hazardous chemicals are present.

Additional training whenever a new chemical hazard is introduced into the work area.

Training must cover:

• The location and availability of the written program and SDSs
• How to read and interpret labels and SDSs
• The physical and health hazards of the chemicals in the work area
• How employees can protect themselves — safe handling procedures, personal protective equipment, engineering controls
• What to do in case of a spill, leak, or exposure emergency
• How to detect the presence or release of a hazardous chemical (visual, odor, monitoring)

Common Compliance Gaps

Incomplete chemical inventories. Walk through every area of your workplace — including maintenance closets, break rooms, and receiving areas — and catalog every hazardous chemical. Include cleaning products, office supplies like toner, and maintenance chemicals.

Missing or outdated SDSs. When you receive a new chemical product, request and file the SDS before employees begin using it. Remove SDSs for chemicals you no longer use (but retain them for 30 years for any chemical employees were exposed to, per OSHA's access to employee exposure and medical records standard).

Training that is too generic. Training must address the specific chemicals employees work with, not just general chemical safety principles. Use your chemical inventory and the relevant SDSs to tailor training to each work area.

Failing to cover non-routine tasks. If employees occasionally perform tasks that expose them to hazardous chemicals they do not normally encounter — such as cleaning a machine with a solvent — they must be informed of the hazards before performing the task.

Getting Started

1. Assign a program coordinator responsible for maintaining the program
2. Conduct a workplace walk-through to inventory all hazardous chemicals
3. Collect SDSs for every chemical on your list
4. Develop or update your written program
5. Label all containers appropriately
6. Train all affected employees and document the training
7. Review and update the program annually

A hazard communication program is one of the most fundamental OSHA requirements. Getting it right protects your employees and demonstrates a basic commitment to workplace safety.