A hazard communication program is a workplace plan that ensures employees know about the chemical hazards they’re exposed to on the job. Required by OSHA under the Hazard Communication Standard (29 CFR 1910.1200), it applies to every employer whose workers may come into contact with hazardous chemicals under normal conditions or in a foreseeable emergency. The standard ranked as the second most frequently cited OSHA violation in fiscal year 2024, which tells you both how important it is and how often workplaces get it wrong.
The program isn’t a single document or checklist. It’s a system with four interlocking parts: a written plan, container labels, safety data sheets, and employee training. If you’re responsible for building or maintaining one, here’s what each piece involves and how they fit together.
Who Needs a Program
The standard covers any employer whose workers could be exposed to hazardous chemicals in the workplace. That’s not limited to chemical plants or laboratories. It includes offices with cleaning supplies, auto shops with solvents, salons with hair treatment products, and construction sites with adhesives and coatings. If a chemical is present and an employee could come into contact with it during normal work or an emergency, the standard applies.
Chemical manufacturers and importers carry an additional responsibility: they must classify the hazards of every chemical they produce or bring into the country. Distributors are required to pass that hazard information along to employers. If your business doesn’t produce or import chemicals, you can focus on the parts of the rule that deal with setting up your workplace program and communicating information to your workers.
The Written Plan
Every employer needs a written hazard communication program. This document serves as the backbone of your compliance effort, spelling out exactly how you’ll handle each requirement of the standard. It must describe your approach to three things: labeling, safety data sheets, and employee training.
The written plan also requires a list of every hazardous chemical known to be present in your workplace. Each chemical on the list should be identified using the same product identifier that appears on its label and safety data sheet, whether that’s a product name, common name, or chemical name. Keeping identifiers consistent makes it far easier to cross-reference your inventory with the correct safety data sheet when you need it. This list isn’t a one-time exercise. It needs to be updated whenever new chemicals enter the workplace or old ones are removed.
Container Labels
Labels are the first line of defense. When a chemical arrives at your workplace in a shipped container, that container must carry a label with six required elements:
- Product identifier: the name that matches the safety data sheet
- Pictogram(s): diamond-shaped symbols indicating hazard types like flammability, toxicity, or corrosion
- Signal word: either “Danger” for more severe hazards or “Warning” for less severe ones
- Hazard statement(s): standardized phrases describing the nature of the hazard
- Precautionary statement(s): recommended measures for safe handling, storage, and emergency response
- Supplier information: name, address, and phone number of the manufacturer or distributor
These elements follow the Globally Harmonized System (GHS), an international framework that standardizes chemical labels so they look and read the same way regardless of where a product was made. If chemicals are transferred into secondary containers in your workplace, those containers generally need labels too, unless the chemical is used immediately by the person who transferred it.
Safety Data Sheets
A safety data sheet (SDS) is a detailed document that accompanies every hazardous chemical. You need one on file for each chemical on your inventory list. The format is standardized into 16 sections, always in the same order: identification, hazard identification, composition and 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 last revision.
The critical requirement is accessibility. Workers must be able to reach the SDS for any chemical in their area during their shift. Many workplaces now use electronic systems, such as computers or tablets, to store and retrieve safety data sheets. That’s allowed, but there’s a catch: you must have a backup system in case of power outages or equipment failures. Workers also need to be trained on how to use the electronic system. In a medical emergency, hard copy safety data sheets must be immediately available to medical personnel.
Employee Training
Training is where the program comes to life. You’re required to provide effective information and training to employees at two points: when they’re first assigned to work with or near hazardous chemicals, and whenever a new chemical hazard is introduced into their work area.
The information component covers three things. Employees need to know that the Hazard Communication Standard exists and what it requires. They need to know which operations in their work area involve hazardous chemicals. And they need to know where to find the written program, the chemical inventory list, and the safety data sheets.
Training goes deeper. It must cover:
- How to detect hazards: methods for recognizing when a chemical has been released, such as monitoring equipment, visual signs, or odor
- Types of hazards present: the physical and health dangers of specific chemicals in the work area, including risks like flammability, cancer, suffocation, combustible dust, and other hazards
- Protective measures: what employees can do to protect themselves, including proper work practices, emergency procedures, and any required protective equipment
- How the program works: how to read shipped container labels, how to understand any workplace labeling system, and how to find and use safety data sheets
Training doesn’t need to be chemical-by-chemical. You can organize it around categories of hazards, like flammability or toxicity, as long as workers can always access chemical-specific details through labels and safety data sheets.
2024 Standard Updates
OSHA published a final rule on May 20, 2024, updating the Hazard Communication Standard to align with the seventh revision of the GHS. The previous version of the standard, last updated in 2012, was based on an earlier GHS revision. The 2024 changes primarily affect how chemicals are classified and what appears on labels and safety data sheets. The goal is better alignment with international standards and with how other federal agencies and Canada handle chemical classification.
The compliance timeline has shifted. In January 2026, OSHA extended all compliance deadlines by four months. Manufacturers, importers, and distributors originally had until January 19, 2026, to evaluate certain substances under the new rules; that deadline moved to May 19, 2026. During the transition, you can comply with the previous version of the standard, the updated version, or both.
Building a Program From Scratch
If you’re starting from zero, work through the components in a logical sequence. First, walk through your workplace and identify every hazardous chemical present. Build your inventory list using the product identifiers on existing labels. Next, collect safety data sheets for every chemical on that list. Contact suppliers for any that are missing. Set up a system, whether physical binders or an electronic database, that makes those sheets accessible to every worker in every area where chemicals are used.
Then write your plan. Document how labels will be maintained (including what happens when chemicals are transferred to secondary containers), where and how safety data sheets will be stored and accessed, and how you’ll train employees. Finally, conduct your initial training and document it. Build in a process for updating the program when new chemicals arrive, when old ones are phased out, or when OSHA requirements change.
The written program should also address how you’ll handle multi-employer worksites. If outside contractors work in your facility, you need a method for sharing chemical hazard information with them, and they need to do the same for you.