The Hazard Communication Standard (29 CFR 1910.1200) — also called HazCom or the "Right to Know" law — requires employers to identify the hazardous chemicals in their workplaces, maintain Safety Data Sheets for each one, label every container, and train workers on the hazards they're exposed to. It applies to virtually every industry that uses chemicals of any kind, from manufacturing facilities to restaurants to office buildings using cleaning products.
Who Must Comply
Any employer whose workers may be exposed to hazardous chemicals under normal conditions or in a foreseeable emergency must comply with HazCom. This is a very broad standard — it covers:
- Manufacturing facilities using process chemicals, lubricants, and solvents
- Construction sites using adhesives, paints, sealants, and fuels
- Healthcare facilities using disinfectants, sterilants, and pharmaceuticals
- Restaurants and food service using commercial cleaning chemicals
- Retail stores using cleaning products
- Offices using toner, cleaning products, or other chemical products
If you buy a product at a hardware store or janitorial supply and use it at work, it's probably covered. If it has a warning label on the container, it almost certainly is.
The 6 Required Elements of a HazCom Program
Every covered employer must have a written Hazard Communication Program. It must address these six elements:
1. Container labeling
Your program must describe how you ensure all containers of hazardous chemicals are properly labeled — both containers received from manufacturers and any secondary containers you transfer chemicals into.
2. Safety Data Sheets
Your program must explain how you obtain and maintain SDS for every hazardous chemical you use, and how workers can access them during their shift.
3. Employee training
Your program must describe how and when you train employees on chemical hazards.
4. List of hazardous chemicals
Your program must reference or include a current list of all hazardous chemicals present in your workplace. This chemical inventory is the backbone of your HazCom program — without it, you cannot know whether your SDS library is complete.
5. Multi-employer workplaces
If you share a worksite with other employers (contractors, subcontractors, etc.), your program must explain how you share hazard information with them and how you receive information from them about chemicals they bring to the site.
6. Non-routine tasks
Your program must address how you communicate chemical hazards to employees who perform non-routine tasks — maintenance work, one-time cleaning operations, or tasks that don't occur in normal production.
Safety Data Sheets (SDS): The 16 Sections Explained
Under OSHA's GHS-aligned HazCom standard, all SDS must follow a standardized 16-section format. Here's what each section contains and which ones matter most for day-to-day compliance:
| Section | Content | Why It Matters |
|---|---|---|
| 1 — Identification | Product name, manufacturer, emergency contact | Emergency response; confirms you have the right SDS |
| 2 — Hazard Identification | GHS classification, signal word, hazard statements, pictograms | Quick hazard summary — start here for training |
| 3 — Composition | Chemical ingredients and concentrations | Identifies what's actually in the product |
| 4 — First Aid Measures | Symptoms and first aid for each exposure route | Critical for emergency response |
| 5 — Fire Fighting | Flammability, extinguishing agents, special hazards | Fire response planning |
| 6 — Accidental Release | Spill cleanup procedures, containment | Spill response |
| 7 — Handling and Storage | Safe handling practices, storage conditions | Preventing incidents before they happen |
| 8 — Exposure Controls/PPE | Permissible exposure limits, PPE requirements, ventilation | Daily use — tells you what protection workers need |
| 9 — Physical/Chemical Properties | Appearance, odor, boiling point, flash point | Hazard recognition; fire risk assessment |
| 10 — Stability/Reactivity | Conditions to avoid, incompatible materials | Storage segregation — critical for chemical safety |
| 11 — Toxicological Info | Routes of exposure, health effects, carcinogenicity | Long-term health risk assessment |
| 12 — Ecological Info | Environmental hazards | Spill reporting requirements |
| 13 — Disposal | Waste disposal methods | Environmental compliance |
| 14 — Transport Info | DOT/IATA/IMDG shipping classification | Shipping and receiving |
| 15 — Regulatory Info | OSHA, EPA, state regulations applicable | Compliance cross-reference |
| 16 — Other Info | Revision date, changes from prior version | Confirms SDS is current |
For day-to-day compliance purposes, train workers to focus on Sections 2, 4, 7, and 8. Those four sections tell them what the hazard is, what to do if something goes wrong, how to handle it safely, and what PPE to use.
SDS Library: Building and Maintaining It
Every employer must have an SDS for every hazardous chemical present in the workplace, and workers must be able to access the SDS during their shift without having to ask a supervisor. Common formats:
- Physical binder: A clearly labeled three-ring binder organized alphabetically or by chemical name, kept in a known location accessible to all workers. Simple and reliable.
- Electronic system: An online SDS management platform or a shared drive folder. Acceptable if workers have computer access during their shift — not acceptable if they'd have to leave the work area or ask for a password.
Building a complete SDS library:
- Start with a complete chemical inventory — walk every area and list every chemical product
- For each chemical, obtain the current SDS from the manufacturer or distributor (most are available on the manufacturer's website)
- Replace any SDS older than the current revision — check Section 16 for the revision date
- Review and update the library whenever new chemicals are introduced
Container Labeling Requirements
Every container of a hazardous chemical must be labeled. GHS-compliant labels from manufacturers must include six required elements:
- Product identifier: The chemical name or product name that matches the SDS
- Signal word: Either "Danger" (more severe hazard) or "Warning" (less severe hazard)
- Hazard statements: Standardized phrases describing the nature of the hazard (e.g., "Causes skin irritation")
- Precautionary statements: Steps to minimize or prevent adverse effects
- Pictogram(s): GHS pictogram(s) appropriate to the hazard classification
- Manufacturer information: Name, address, and phone number
Secondary containers — any container you transfer a chemical into — must also be labeled. The label must include at minimum the product identifier and appropriate hazard warnings. A container labeled "stuff" or left completely unlabeled is a violation regardless of how small the quantity or how briefly it will be used.
The 9 GHS Pictograms
| Pictogram | Hazard | Examples |
|---|---|---|
| Flame | Flammable, self-reactive, pyrophoric | Gasoline, acetone, some aerosols |
| Flame over circle | Oxidizer | Hydrogen peroxide, chlorine bleach |
| Exploding bomb | Explosive, self-reactive, organic peroxide | Certain peroxides, unstable explosives |
| Gas cylinder | Gases under pressure | Compressed gas cylinders, LPG |
| Corrosion | Skin/eye corrosion, metal corrosion | Acids, strong bases, bleach |
| Skull and crossbones | Acute toxicity (fatal/toxic) | Certain pesticides, some industrial solvents |
| Exclamation mark | Irritant, harmful, narcotic effects | Many cleaning products, mild irritants |
| Health hazard | Carcinogen, reproductive toxin, sensitizer, STOT | Formaldehyde, benzene, isocyanates |
| Environment | Aquatic toxicity | Some solvents, pesticides (voluntary on OSHA labels) |
Employee Training Requirements
Training must be provided at the time of initial assignment and whenever a new hazard is introduced to the workplace. Training must cover:
- The requirements of the HazCom standard and where to find the written program
- Any operations in their work area where hazardous chemicals are present
- The location and availability of the SDS library
- Methods to detect the presence or release of hazardous chemicals (visual appearance, odor, monitoring)
- The physical and health hazards of the chemicals in their work area
- Measures workers can take to protect themselves (PPE, engineering controls, work practices)
- How to read and understand a GHS label
- How to read and use an SDS — specifically Sections 2, 4, 7, and 8
Training must be documented. Keep records showing the employee's name, the date, and what was covered. A sign-in sheet from a group training session with an agenda attached is sufficient.
Multi-Employer Worksite Requirements
When contractors bring hazardous chemicals onto a job site, they must provide SDS for those chemicals to the host employer. The host employer must ensure visiting contractors know about chemicals already present on the site. This is frequently overlooked on construction sites and in facilities that use service contractors.
Best practice: include a HazCom information exchange requirement in all contractor agreements, and designate a specific person responsible for the exchange at the start of each project.
Most Common HazCom Violations
| Violation | How to Fix It |
|---|---|
| No written HazCom program | Write one — templates available at OSHA.gov and on our checklists page |
| Incomplete SDS library | Conduct a full chemical inventory; obtain missing SDS from manufacturers |
| Unlabeled secondary containers | Label every container with product name and hazard warning before filling |
| SDS not accessible during shift | Place binder in accessible, known location — or ensure electronic access during work hours |
| No training documentation | Document all training with names, dates, and content covered |
| Outdated SDS | Check revision dates; replace SDS older than the current manufacturer version |
| No chemical inventory list | Walk every area and create a master list of all chemicals present |