A hazard communication program is the written plan OSHA requires every employer that uses hazardous chemicals to develop, implement, and maintain at each workplace under 29 CFR 1910.1200(e)(1). It must describe how the employer meets the standard’s requirements for labels, safety data sheets, and employee training, and it must include a list of the hazardous chemicals known to be present.
If an OSHA compliance officer walks into your plant, the written program is usually the first document requested. Everything else — container labels, the SDS binder or portal, training records — is checked against what the program says you do. This guide breaks down what the standard actually requires, document by document, and where your chemical supplier fits into the chain.
What must a written hazard communication program contain?
Under 29 CFR 1910.1200(e)(1), employers must develop, implement, and maintain a written program at each workplace. The standard names the elements it has to cover.
| Required element | Citation | What it means in practice |
|---|---|---|
| How labels and other forms of warning are handled | 1910.1200(e)(1) | Describes your workplace labeling system and who maintains it |
| How safety data sheets are handled | 1910.1200(e)(1) | Describes how SDSs are obtained, stored, and made accessible |
| How employee information and training are handled | 1910.1200(e)(1) | Describes training content, timing, and documentation |
| A list of the hazardous chemicals known to be present | 1910.1200(e)(1)(i) | Uses the product identifier that appears on the matching SDS; may be site-wide or by work area |
| Methods for non-routine tasks and unlabeled pipes | 1910.1200(e)(1)(ii) | Covers jobs like vessel cleaning and chemicals in unlabeled piping |
The chemical list is where most programs fall apart. OSHA requires the product identifier on the list to match the identifier on the safety data sheet. If purchasing switches suppliers or grades and nobody updates the list, the list and the SDS library drift apart.
How must safety data sheets be kept?
OSHA requires the employer to maintain copies of the required safety data sheets for each hazardous chemical in the workplace, and to ensure they are readily accessible during each work shift to employees when they are in their work areas — 1910.1200(g)(8).
Electronic access is explicitly permitted. The standard allows electronic access and other alternatives to paper copies as long as no barriers to immediate employee access in each workplace are created by such options. A tablet on the production floor is fine. A PDF library that only the EHS manager can log into is not.
For employees who travel between workplaces during a shift, 1910.1200(g)(9) allows the safety data sheets to be kept at the primary workplace facility.
Learn how to read the document itself in our guide to the 16 sections of a safety data sheet.
What must a chemical container label include?
Labels on shipped containers are the supplier’s obligation. Under 1910.1200(f)(1), the chemical manufacturer, importer, or distributor must ensure each container of hazardous chemicals leaving the workplace carries six elements.
| # | Label element | Citation |
|---|---|---|
| 1 | Product identifier | 1910.1200(f)(1)(i) |
| 2 | Signal word | 1910.1200(f)(1)(ii) |
| 3 | Hazard statement(s) | 1910.1200(f)(1)(iii) |
| 4 | Pictogram(s) | 1910.1200(f)(1)(iv) |
| 5 | Precautionary statement(s) | 1910.1200(f)(1)(v) |
| 6 | Name, U.S. address, and U.S. telephone number of the manufacturer, importer, or other responsible party | 1910.1200(f)(1)(vi) |
Workplace labeling is a separate, looser requirement. Under 1910.1200(f)(6), each container of hazardous chemicals in the workplace must be labeled with either the full shipped-container information, or the product identifier plus words, pictures, or symbols giving general hazard information that works alongside the rest of your program.
Our walkthrough of how to read a GHS label on a chemical drum covers what each element looks like on a real drum.
What must hazard communication training cover?
Training is required at the time of initial assignment and whenever a new chemical hazard employees have not previously been trained about is introduced into their work area — 1910.1200(h)(1). The standard lists four minimum training topics under 1910.1200(h)(3):
- Methods and observations used to detect the presence or release of a hazardous chemical in the work area, such as employer monitoring, continuous monitoring devices, or visual appearance and odor
- The physical, health, simple asphyxiation, combustible dust, and pyrophoric gas hazards, plus hazards not otherwise classified, of the chemicals in the work area
- The measures employees can take to protect themselves, including work practices, emergency procedures, and personal protective equipment
- The details of the employer’s hazard communication program
Note the trigger: a new chemical hazard, not simply a new product. Swapping one acetone supplier for another does not trigger retraining. Adding a first aromatic solvent to a plant that previously ran only alcohols does.
Where does your chemical supplier fit in?
Three of the documents an auditor asks for originate upstream, with the manufacturer or distributor: the shipped-container label, the safety data sheet, and the certificate of analysis that ties a specific lot to a specific specification. A supplier that is slow with documents becomes your compliance gap.
Practical questions worth asking any distributor before you buy:
- Is the current SDS available without a login or a phone call?
- Does the product identifier on the SDS match the label and the invoice line?
- Is a certificate of analysis issued per lot, and does it reference the same identifier?
- Does the shipping paperwork carry the correct DOT hazard class and UN number for the material?
RightPath Industries maintains a public SDS library covering the chemicals we distribute, so EHS teams can pull current documents without waiting on a sales rep.
What grades and sizes do we stock?
RightPath Industries distributes more than 8,000 chemicals from our Pittsburgh headquarters, spanning acetates, acids, alcohols, aromatics, bromine chemicals, glycols, high purity analytical solvents, powdered chemicals and salts, and solvents. Common industrial solvents such as acetone ship in gallons, pails, drums, totes, and bulk, packed to your specification and lot-controlled on request.
How do you order from RightPath?
Send the product identifier, grade, packaging size, and destination, and we will return pricing with the documentation package attached. Request bulk pricing or call our Pittsburgh office to speak with a sourcing specialist.
Frequently asked questions
Is a written hazard communication program required for every workplace?
OSHA requires employers to develop, implement, and maintain a written hazard communication program at each workplace where hazardous chemicals are used, under 29 CFR 1910.1200(e)(1). The program is site-specific, so a company with three plants generally maintains three programs.
Can safety data sheets be stored electronically instead of in a binder?
Yes. 29 CFR 1910.1200(g)(8) permits electronic access and other alternatives to paper copies, provided no barriers to immediate employee access are created in each workplace during every work shift.
How often is hazard communication training required?
OSHA requires training at the time of initial assignment and whenever a new chemical hazard that employees have not previously been trained about is introduced into their work area, under 29 CFR 1910.1200(h)(1). The standard does not set a fixed annual interval.
Who is responsible for labeling a drum of solvent that arrives at my plant?
The chemical manufacturer, importer, or distributor is responsible for the label on the shipped container under 29 CFR 1910.1200(f)(1). Once the material is transferred to workplace containers, the employer is responsible for workplace labeling under 1910.1200(f)(6).
Does the chemical list have to match the safety data sheets?
Yes. 29 CFR 1910.1200(e)(1)(i) requires the list of hazardous chemicals to use a product identifier that is referenced on the appropriate safety data sheet.