OSHA Hazard Communication: Keeping Workers Safe

The principle is simple. Compliance is not.

Every worker has the right to know what they're being exposed to. That's the whole idea behind OSHA's Hazard Communication Standard — 29 CFR 1910.1200, often shortened to HazCom, and sometimes called the “Right to Know” standard.

It is also, year after year, the second most frequently cited standard in the country. Which tells you something: the principle is simple, and compliance is not.

The problem isn't that employers reject the idea. It's that HazCom is a system — written program, labels, safety data sheets, and training, all of which have to stay current as chemicals, containers, and people move through a workplace. Systems decay quietly. That's why HazCom shows up on the citation list every single year.

Here's what the standard actually requires, and where it breaks down.

Who It Applies To

Nearly everyone. HazCom covers any workplace where employees may be exposed to hazardous chemicals under normal conditions of use or in a foreseeable emergency.

This is broader than most employers assume. The most-cited industry for HazCom violations in FY2025 was roofing — not a chemical plant, not a manufacturer. Roofing.

If your operation uses solvents, adhesives, fuels, cleaning products, paints, sealants, disinfectants, lubricants, resins, or gases, you're covered. “We're not a chemical company” is not a defense. The standard doesn't care about your industry classification; it cares about what's on your shelves.

There are limited exemptions — certain consumer products used the way a consumer would use them, articles that don't release chemicals, food and drugs in retail — but they're narrower than people hope, and misapplying them is itself a common failure.

The Four Pillars

HazCom compliance rests on four interlocking pieces. Fail one and the system doesn't work.

1. The Written Program

You need a written hazard communication program. Not a binder purchased in 2014. Not a template with another company's name still in it.

The program must describe how your workplace handles labels, safety data sheets, and training. It must include a list of the hazardous chemicals present. And for multi-employer worksites, it must describe how you'll inform contractors' employees about hazards they may encounter — a requirement construction employers routinely overlook.

The core test: does the document describe what actually happens here? If an inspector reads your program and then walks your floor, the two should match. When they don't, the program isn't documentation — it's a written admission that you know the requirement and aren't meeting it.

2. Labels

Every container of a hazardous chemical needs to be labeled.

Shipped containers, from the manufacturer, must carry six elements under the GHS-aligned system:

• Product identifier
• Signal word (Danger or Warning)
• Hazard statement(s)
• Pictogram(s)
• Precautionary statement(s)
• Name, address, and phone number of the responsible party

Where employers get cited: secondary containers. The moment someone decants solvent from a drum into a spray bottle, that bottle needs a label. The unlabeled spray bottle under the sink is the single most photographed HazCom violation in America.

Workplace labels don't have to replicate the full shipped-container format — you can use an alternative system as long as it conveys the product identifier and the hazard information effectively, and workers understand it. But something is required. “Everyone knows what's in it” is not a labeling system. It's an assumption that fails the moment a new hire, a temp, or a paramedic walks in.

The narrow exception is the portable container into which a chemical is transferred and which is used immediately by the person who transferred it, within one shift. Set it down, leave it overnight, or hand it to someone else, and the exception evaporates.

3. Safety Data Sheets

An SDS is required for every hazardous chemical in the workplace, in a standardized 16-section format, and it must be readily accessible to employees during their work shifts.

“Readily accessible” is where this fails. An SDS in a locked office. An SDS on a server nobody can reach from the shop floor. An SDS in a binder the supervisor keeps in his truck. A digital system with no backup when the network is down. All of these have generated citations.

The practical standard: can a worker — not a manager, a worker — get to the SDS for the chemical in front of them, right now, without asking permission and without leaving the work area for long?

Other recurring failures:

• SDSs missing for chemicals that are actually on site
• SDSs kept for chemicals that were discontinued years ago, while new ones went unfiled
• Manufacturer sends an updated SDS; nobody swaps it into the binder
• The chemical inventory list and the SDS collection don't match each other

4. Training

Employees must be trained at the time of initial assignment, and again whenever a new chemical hazard is introduced into their work area.

Training must cover:

• The requirements of the standard itself
• Where hazardous chemicals are present in their work area
• Where the written program, chemical list, and SDSs are located
• How to detect the presence or release of a hazardous chemical
• The physical and health hazards of the chemicals present
• Protective measures — work practices, engineering controls, PPE, emergency procedures
• How to read and use labels and SDSs

And critically: training must be in a language and at a literacy level the workers actually understand. A training video in English shown to a crew that speaks Spanish is not training. It's a compliance artifact.

The Pictograms

Nine pictograms carry the GHS hazard classes. Workers should be able to recognize them on sight:

Note the two that get confused: skull and crossbones means it can kill you quickly. Health hazard — the silhouette with the starburst in the chest — means it can kill you slowly. Workers routinely treat the second as less serious. It's the one that causes cancer.

Why HazCom Fails

Look at the failure modes and a pattern emerges. HazCom violations are almost never a refusal to comply. They're erosion.

• The written program was accurate when it was written, and the process changed.
• The SDS binder was complete, and then a new supplier shipped a new product.
• The labeling was fine, and then someone needed a spray bottle in a hurry.
• Training was thorough, and then three people were hired in a busy month and the onboarding got compressed.

These are symptoms of disorganized documentation and inconsistent onboarding practices, not bad intent. Which is precisely why they recur — nobody is watching for a failure that happens by drift.

Building a HazCom Program That Holds

Do a real chemical inventory, and own it. Walk the site. Every cabinet, shed, truck, and shelf. Reconcile the list against the SDS collection in both directions: every chemical has a sheet, and every sheet has a chemical.

Make receiving the control point. New chemicals enter through purchasing and receiving. That's the choke point. If nothing gets shelved until its SDS is filed and its container is verified as labeled, the system stays current on its own. If you rely on periodic audits to catch drift, you'll always be behind.

Put labels within arm's reach of where they're needed. Preprinted secondary-container labels, a label printer in the shop, blank workplace labels at the decanting station. The unlabeled spray bottle exists because labeling it was inconvenient. Remove the inconvenience.

Test SDS access the way a worker would. Go to the floor. Ask someone to pull up the SDS for the product they're using. Time it. If they can't, or it takes ten minutes, or they say “ask Dave” — you have a finding, and you found it before OSHA did.

Train in the language people speak. This isn't just a compliance requirement; it's the difference between training and theater.

Trigger updates on change, not on the calendar. New chemical, new process, new supplier, new hire — each is an event that requires an action. An annual review will not catch a chemical that arrived in March.

The Underlying Point

Strip away the paperwork and HazCom is a simple proposition: a person handling a substance is entitled to know what it will do to them.

Everything else — the pictograms, the sixteen sections, the written program — is machinery built to deliver that one thing reliably, to someone who wasn't in the room when the decision was made, on a shift when the supervisor is off, in an emergency when there's no time to ask.

The unlabeled spray bottle isn't a paperwork violation. It's a bet that nobody will pick it up who doesn't already know.

This article is general information, not legal advice or a compliance determination. Requirements are subject to revision, and specific obligations depend on your operations, industry, and jurisdiction (including state-plan states with additional requirements). Consult 29 CFR 1910.1200 and a qualified safety professional for your situation.