OSHA Hazard Communication Standard (1910.1200): the HazCom compliance guide

By Cairn

1. A written hazard communication program

   1910.1200(e)(1)

   A document at each site describing how you handle labels, safety data sheets, and training. It must include a list of the hazardous chemicals present and the methods used to inform employees about non-routine tasks.

   "Employers shall develop, implement, and maintain at each workplace, a written hazard communication program which at least describes how the criteria specified in paragraphs (f), (g), and (h) of this section for labels and other forms of warning, safety data sheets, and employee information and training will be met…"

2. A list (inventory) of hazardous chemicals

   1910.1200(e)(1)(i)

   A maintained inventory of every hazardous chemical in the workplace, identified by the same product identifier used on its SDS, so each entry traces to a sheet.

   "A list of the hazardous chemicals known to be present using a product identifier that is referenced on the appropriate safety data sheet (the list may be compiled for the workplace as a whole or for individual work areas)…"

3. Labels and other forms of warning

   1910.1200(f)

   Shipped containers carry full GHS labels (product identifier, signal word, hazard and precautionary statements, pictograms, supplier contact). Workplace containers must at minimum show the product identifier and words/pictures/symbols conveying the hazards.

   "The chemical manufacturer, importer, or distributor shall ensure that each container of hazardous chemicals leaving the workplace is labeled, tagged or marked… [with] product identifier; signal word; hazard statement(s); pictogram(s); precautionary statement(s); and… name, address, and telephone number of the… responsible party."

4. Safety data sheets (SDS)

   1910.1200(g)

   A 16-section SDS for every hazardous chemical, kept readily accessible to employees on every shift in their work area, reachable without first asking a manager to unlock a file.

   "Employers shall have a safety data sheet in the workplace for each hazardous chemical which they use… [and] shall ensure that the safety data sheets are readily accessible during each work shift to employees when they are in their work area(s)."

5. Employee information and training

   1910.1200(h)(1)

   Training at initial assignment and whenever a new hazard is introduced, covering how to read labels and SDS, the physical and health hazards present, and the details of your written program.

   "Employers shall provide employees with effective information and training on hazardous chemicals in their work area at the time of their initial assignment, and whenever a new chemical hazard the employees have not previously been trained about is introduced into their work area."

6. Hazard classification

   1910.1200(d)(1)

   Manufacturers and importers classify each chemical by hazard class and category against Appendices A, B, and C. Employers who use chemicals rely on this classification but must still maintain the program above for what they receive.

   "Chemical manufacturers and importers shall evaluate chemicals produced in their workplaces or imported by them to classify the chemicals in accordance with this section. For each chemical, the chemical manufacturer or importer shall determine the hazard classes, and where appropriate, the category of each class that apply to the chemical being classified."

The two HazCom paragraphs most often cited are the written program, 1910.1200(e)(1), and employee training, 1910.1200(h)(1). Both appear near the top of the citation record in every manufacturing sector. Counts below are federal OSHA citations from the enforcement record.

Source: federal OSHA citation record (all years). NAICS sectors as defined by the U.S. Census North American Industry Classification System.

• ▢ Is there a written HazCom program at each site, naming the person responsible? 1910.1200(e)(1)
• ▢ Is the chemical inventory current, with each entry tied to an SDS product identifier? 1910.1200(e)(1)(i)
• ▢ Are all workplace containers labeled with the identifier and a hazard warning? 1910.1200(f)(6)
• ▢ Is an SDS readily accessible on every shift for every hazardous chemical? 1910.1200(g)(8)
• ▢ Were employees trained at initial assignment and when new hazards were introduced? 1910.1200(h)(1)

What is the OSHA Hazard Communication Standard (HazCom)? +

What are the six required elements of a HazCom program? +

Who has to comply with 1910.1200? +

How often is HazCom training required? +

Does HazCom require a safety data sheet for every chemical? +

How much do HazCom violations cost? +

This guide summarizes 29 CFR 1910.1200 for general reference; it is not legal advice. Always confirm a requirement against the controlling text on osha.gov or eCFR, and check whether your state runs an OSHA-approved State Plan with its own adopted version.