Understanding OSHA's HazCom Standard and Training Requirements

Sam Spaccamonti
6 hours ago
10 min read

Quick Answer: OSHA’s Hazard Communication Standard (HazCom), codified at 29 CFR 1910.1200, requires employers to inform and train employees about hazardous chemicals in the workplace. A compliant HazCom program includes a written hazard communication program, chemical inventory, proper labeling, accessible Safety Data Sheets (SDSs), and employee training before exposure and when new chemical hazards are introduced.

What Is OSHA's Hazard Communication Standard?

OSHA's Hazard Communication Standard (HazCom), also known as 29 CFR 1910.1200, requires employers to inform employees about hazardous chemicals in their workplace and provide the information and training needed to work with those chemicals safely. The standard requires employers to maintain a written HazCom program, chemical inventory, proper labels, accessible Safety Data Sheets (SDSs), and employee training.

The core premise of the standard is straightforward: workers have a fundamental right to know about the hazardous substances they work with, and employers have a legal obligation to provide that information in a form that is clear, consistent, and actionable. The standard achieves this through four primary requirements that together form the foundation of any compliant HazCom program.

1. History and Development of OSHA's HazCom Standard

OSHA first implemented the standard in 1983, originally covering only the manufacturing sector. It was expanded in 1987 to encompass all industries in which employees may be exposed to chemicals.

2. 2012 GHS Update

The most transformative revision came in 2012, when OSHA aligned the standard with the third revision of the United Nations' Globally Harmonized System of Classification and Labelling of Chemicals.

That update introduced the now-familiar 16-section Safety Data Sheet format, standardized GHS pictograms, and harmonized hazard classification criteria that replaced the inconsistent, format-free Material Safety Data Sheets that had been in use since the standard's inception.

3. 2024 HazCom Update

In May 2024, OSHA published another significant final rule, this time aligning the HCS with the seventh and eighth revisions of the UN GHS. The rule took effect on July 19, 2024, with phased compliance deadlines: January 19, 2026, for substances and July 19, 2027, for mixtures, with employer training updates required to be completed within two years of the rule's publication.

What Are the Four Core Components of a HazCom Program?

A compliant HazCom program has four core components: a written hazard communication program, a chemical inventory, proper labeling and pictograms, and accessible Safety Data Sheets (SDSs). Together, these requirements help employers identify chemical hazards and ensure employees have the information they need to work safely.

1. Written Hazard Communication Program

A written HazCom program explains how an employer identifies and manages hazardous chemicals in the workplace and how employees are protected from those hazards.

Every employer covered by HazCom must have a written hazard communication program that documents how the facility will meet each of the standard's requirements. This is not a generic downloaded template. It must reflect the actual operations of the specific workplace, including the specific chemicals used, the locations where they are used, who has access to Safety Data Sheets, how new employees will be trained, and how the program will be updated when new hazards are introduced.

The written program must be made available to employees, their designated representatives, and OSHA compliance officers upon request. It must also identify the person or persons responsible for maintaining the chemical inventory, managing SDS files, and ensuring label compliance.

A missing or outdated written program is among the most common HazCom violations cited during inspections. A program that was written when the facility opened and has never been updated to reflect changes in chemicals, processes, or staffing is not a compliant program.

2. Chemical Inventory

A chemical inventory is a current list of all hazardous chemicals present in the workplace, along with their corresponding labels and Safety Data Sheets.

The HazCom standard requires employers to maintain a master list of all hazardous chemicals present in the workplace. This inventory serves as the cross-reference between the physical chemicals in the facility, their corresponding labels, and their Safety Data Sheets. Every chemical on the inventory must have an accessible SDS, and every container of that chemical must be labeled in accordance with the standard.

Conducting the inventory requires a physical walkthrough of the facility to identify all hazardous chemicals in every department, storage area, and utility space. Many compliance officers also recommend engaging department heads to identify chemicals that may not be centrally tracked, particularly in settings where different departments source their own supplies independently.

The inventory must be kept current. Adding a new chemical to the workplace without updating the inventory, securing the corresponding SDS, and training affected employees is a compliance failure at multiple levels simultaneously.

3. Labels and Pictograms

HazCom requires hazardous chemical containers to have clear labels that identify the chemical and communicate its potential hazards, precautions, and supplier information.

Container labeling is one of the most visible and most immediately practical elements of HazCom compliance. Under the GHS-aligned standard, every container of a hazardous chemical must display six required label elements.

The product identifier is the chemical name or number that links the container to its entry in the inventory and its corresponding SDS. The signal word is either DANGER, for more severe hazards, or WARNING, for less severe ones, and only one signal word appears per label regardless of how many hazards a chemical presents.

Hazard statements are standardized phrases that describe the nature of the hazard and its degree, such as "Causes severe skin burns and eye damage" or "May cause cancer."

Precautionary statements describe the recommended measures to minimize or prevent adverse effects, covering prevention, response, storage, and disposal. Pictograms are the eight standardized GHS symbols enclosed in a red diamond border on a white background, each communicating a category of hazard at a glance.

The eight pictograms cover health hazards, flammables, explosives, oxidizers, compressed gases, corrosives, environmental hazards, and acute toxicity. Finally, supplier information includes the name, address, and telephone number of the manufacturer, importer, or other responsible party.

For shipped containers, labeling requirements apply at the point of manufacture or import. For workplace containers, including secondary containers where chemicals have been transferred from their original packaging, employers must ensure that labels are maintained and legible at all times. Pipes are not considered containers under the standard and do not require HCS labels, but employees must be trained on the hazards of chemicals flowing through unlabeled pipes.

The 2024 final rule introduced updates to labeling requirements for very small containers, bulk chemical shipments, and situations where DOT transportation pictograms are present on shipped containers, in which case the corresponding HCS pictogram for the same hazard is not also required.

4. Safety Data Sheets (SDSs)

Safety Data Sheets (SDSs) provide detailed information about a hazardous chemical, including its hazards, safe handling, storage, emergency response, and disposal.

Safety Data Sheets are comprehensive technical documents that accompany every hazardous chemical and provide detailed information about its properties, hazards, safe handling, storage, emergency response, and disposal.

The 16 sections cover identification, hazard identification, composition and information on ingredients, first-aid measures, fire-fighting measures, accidental release measures, handling and storage, exposure controls and personal protection, physical and chemical properties, stability and reactivity, toxicological information, ecological information, disposal considerations, transport information, regulatory information, and other information including the date of preparation or last revision.

OSHA enforces sections 1 through 11 and section 16. Sections 12 through 15 covering ecological information, disposal, transport, and regulatory data must be included in the SDS format, but OSHA defers enforcement of those sections to other federal agencies with jurisdiction over those areas.

SDSs must be readily accessible to employees during all work shifts. Accessibility means that an employee should be able to review the SDS for any chemical they work with without having to ask a supervisor for permission or wait for someone to retrieve it. Electronic SDS systems are acceptable provided employees can access them immediately and a backup system exists for situations where electronic access is unavailable.

The employer is responsible for ensuring that SDS files are kept current. When a manufacturer releases an updated SDS for a product in use, the workplace file must be updated. Maintaining SDSs for products that have been discontinued or replaced without reflecting those changes in the inventory is a frequent and avoidable compliance gap.

HazCom Training Requirements at a Glance

Requirement	What It Means
Who needs training?	Employees who may be exposed to hazardous chemicals
Initial training	Before working in an area with hazardous chemicals
New hazards	Training required when a new chemical hazard is introduced
Language	Training must be understandable to employees
Topics	Chemical hazards, labels, pictograms, SDSs, protective measures
Documentation	Maintain records showing who was trained, when, and on what

What Changed in OSHA's 2024 HazCom Update?

OSHA's 2024 HazCom update revised hazard classification, labeling, and other requirements to align the standard with newer GHS revisions. The rule became effective July 19, 2024, with different compliance deadlines for substances, mixtures, and employee training.

What Changed?

The 2024 HazCom update introduced changes to hazard classification, labeling, and Safety Data Sheet requirements, primarily to align OSHA’s standard with GHS Revision 7. It updated criteria for certain health and physical hazards, added requirements for very small containers and bulk shipments, and made other technical changes to improve how chemical hazards are communicated. Employers also need to review updated chemical classifications, labels, and SDSs to ensure their workplace information remains accurate.

What Did Not Change?

Area	2024 Update
Hazard classification	Updated for certain hazard classes
Labels	Updated requirements for certain containers and shipments
SDSs	Updated classifications may require revised SDSs
Training	Employees need updated training within the applicable deadline
Core HazCom structure	Remains in place

How to Maintain HazCom Compliance?

Maintain a current chemical inventory.
Keep SDSs readily accessible.
Check labels on primary and secondary containers.
Maintain the written HazCom program.
Train employees before exposure.
Train employees when new chemical hazards are introduced.
Keep training documentation.
Review SDSs and labels when manufacturers issue updates.
Periodically audit the program for gaps.

What Are the Most Common HazCom Violations?

HazCom violations often occur when employers do not keep their chemical information, labeling, and employee training up to date. The most common issues include missing Safety Data Sheets, inadequate training, unlabeled secondary containers, and outdated chemical inventories or written programs.

1. Missing or Inaccessible Safety Data Sheets

Missing or inaccessible Safety Data Sheets are the single most commonly cited violation. Employers who assembled a complete SDS binder when the facility opened but never added SDSs for new chemicals or replaced discontinued ones over the years end up with a file that is outdated and incomplete without ever noticing the drift.

2. Inadequate Employee Training

Inadequate employee training, or training that cannot be demonstrated through documentation, is the second most commonly cited pattern. Workplaces where training was conducted during a past compliance push and then allowed to lapse as new employees were added without corresponding training create a gap that becomes apparent when an inspector asks to see records for every employee with chemical exposure.

3. Unlabeled or Improperly Labeled Secondary Containers

Unlabeled or improperly labeled secondary containers are another frequent citation source. When chemicals are transferred from their original containers into secondary containers for operational convenience, those secondary containers must be labeled. A squeeze bottle of industrial cleaner with no label in a maintenance closet is a violation regardless of how obvious its contents may seem to employees who use it daily.

Avoiding these violations requires building maintenance habits into the HazCom program rather than treating compliance as a one-time event. Quarterly reviews of the SDS inventory against the chemical inventory, a documented process for adding new chemicals to the program, and an annual verification of training records for all employees with chemical exposure are the operational disciplines that keep a compliant program compliant over time.

OSHA HazCom Standard at a Glance

Standard: 29 CFR 1910.1200 Purpose: Protect employees from hazardous chemical exposure Core requirements: Written program, chemical inventory, labels, SDSs, and training Training: Required before initial exposure and when new chemical hazards are introduced SDS format: 16 sections Regulatory framework: OSHA Hazard Communication Standard / GHS-aligned requirements

Frequently Asked Questions (FAQs)

Q1: Who is required to comply with OSHA's Hazard Communication Standard?

The HazCom standard applies to any employer whose employees may be exposed to hazardous chemicals in the course of their work. This encompasses virtually all industries: manufacturing, construction, healthcare, agriculture, retail, education, and service sectors are all covered if hazardous chemicals are present in the workplace. Chemical manufacturers and importers have additional obligations under the standard, including classifying chemicals and producing compliant labels and Safety Data Sheets. Even employers who do not use chemicals directly but whose employees may encounter chemicals brought on-site by contractors are responsible for ensuring that employees have access to SDS information for those chemicals and receive appropriate training.

Q2: What is the difference between a Material Safety Data Sheet and a Safety Data Sheet?

A Material Safety Data Sheet (MSDS) was the pre-2012 format for chemical hazard documentation. MSDSs had no standardized section structure, which meant that the same type of information could appear in a different location on every document, making them difficult to use quickly and consistently. The 2012 HazCom update replaced MSDSs with Safety Data Sheets (SDSs), which follow a mandatory 16-section format aligned with the UN's Globally Harmonized System. The SDS format places specific categories of information in the same location on every document, making it far easier for employees, emergency responders, and safety professionals to find what they need quickly. All MSDS documents should have been converted to compliant SDS format by the June 1, 2016 deadline. Any workplace still maintaining MSDS documents in place of GHS-compliant SDSs is not in compliance with the current standard.

Q3: What does the 2024 HazCom final rule change for employers, and when do they need to comply?

The May 2024 final rule updated OSHA's Hazard Communication Standard to align it primarily with the seventh revision of the UN's Globally Harmonized System. The key changes for employers involve updated hazard classification criteria for specific hazard classes, which means some chemicals may now be classified differently than before even if the product itself has not changed. Employers should review their chemical inventories to identify products with updated SDSs and ensure that labels and training reflect any new classification information. The rule took effect July 19, 2024. The phased compliance deadlines require chemical manufacturers and importers to comply with updated SDS and labeling requirements for substances by January 19, 2026, and for mixtures by July 19, 2027. Employers must update training for affected employees within two years of the July 2024 effective date, placing the employee training deadline in July 2026.

Q4: What are the penalties for violating the HazCom standard?

OSHA penalties for HazCom violations are governed by the same penalty structure as all other OSHA standards. As of 2025, the maximum penalty for a serious violation is $16,550 per violation. Willful or repeated violations carry maximum penalties of $165,514 per citation. Failure-to-abate penalties accrue at $16,550 per day after the abatement deadline. Because HazCom violations often exist as clusters, with a missing SDS, an unlabeled container, and an undocumented training gap all present simultaneously, a single inspection can identify multiple violations that compound into a substantial total penalty. Beyond direct financial penalties, OSHA inspections that uncover significant HazCom non-compliance frequently result in increased regulatory scrutiny, follow-up inspections, and reputational consequences that can affect employee relations and client relationships.