HazCom Written Program: What to Include

OSHA's Hazard Communication Standard (29 CFR 1910.1200) requires every employer who uses hazardous chemicals to maintain a written Hazard Communication program. Not a mental plan. Not a verbal understanding. A written document that describes how your company handles chemical safety.

It's the first thing OSHA inspectors ask for during a HazCom inspection — and one of the most commonly cited violations when it's missing, generic, or outdated.

If you don't have one, or yours is a template you downloaded three years ago and never updated, this guide will walk you through exactly what needs to be in it.

What Is a Written HazCom Program?

A written HazCom program is a document that describes how your company implements each element of the [OSHA Hazard Communication Standard](/blog/what-is-hazcom). It's your company's specific plan for how you:

• Identify hazardous chemicals in the workplace
• Maintain Safety Data Sheets
• Label chemical containers
• Train employees on chemical hazards
• Handle non-routine chemical tasks
• Share hazard information with contractors

Think of it as the operating manual for your entire chemical safety program. Everything else — your [chemical inventory](/blog/ehs-chemical-inventory-management-guide), your [SDS collection](/blog/what-is-sds), your training records — is an element that the written program ties together.

Who Needs a Written HazCom Program?

Every employer covered by the OSHA Hazard Communication Standard needs one. That includes:

• Any business where employees handle, use, or are exposed to hazardous chemicals — even common cleaning products, paints, or adhesives
• Multi-site operations — each site needs its own program (or a master program with site-specific addenda)
• Businesses with contractors on-site — the program must address how you share hazard information with outside workers

If you have 5 employees and a janitor's closet full of cleaning supplies, you need a written program. If you're a manufacturer with 500 chemicals across 10 buildings, you need a written program. The scale is different, but the requirement is the same.

The 7 Elements Every Written HazCom Program Must Include

1. Program Scope and Responsibilities

Your program must state:

• Who is covered — which employees, departments, and work areas fall under the program
• Who is responsible — name the person (by title or name) responsible for maintaining the program, managing SDSs, coordinating training, and overseeing labeling
• Where the program applies — identify each worksite covered

Don't write "management is responsible." OSHA wants to see a specific person or role. For a small business, it might be the owner. For a larger operation, it might be the EHS manager or safety coordinator.

Example language: > "This Hazard Communication Program applies to all employees at [Company Name]'s facility located at [Address]. The Safety Manager, [Name/Title], is responsible for maintaining this program, ensuring SDS availability, coordinating employee training, and overseeing container labeling."

2. Chemical Inventory List

Your written program must describe:

• How you maintain your chemical inventory — what system you use (software, spreadsheet, paper list) and how often it's updated
• Where the inventory is kept — employees need to know where to find it
• How new chemicals are added — the process for adding a new product to the inventory before it enters the workplace

The inventory itself can be a separate document, but the written program must reference it and explain how it's managed. For a complete guide to building your inventory, see [EHS Chemical Inventory Management: The Complete Guide](/blog/ehs-chemical-inventory-management-guide).

What inspectors look for: They'll compare your inventory list against what's actually on your shelves. If there's a chemical on the shelf that's not on your list, that's a finding. If your program says you update the inventory "monthly" but the list was last updated 8 months ago, that's a finding too.

3. Safety Data Sheet Management

Your program must describe:

• How SDSs are obtained — who requests them, where they come from, and the process for new chemicals
• How SDSs are maintained — where they're stored (binder, shared drive, software platform) and how they're organized
• How SDSs are made accessible — employees must be able to access SDSs during every work shift without asking permission
• What happens when an SDS is missing — the procedure for obtaining a missing SDS and whether work can continue without one

"Readily accessible" is the key phrase. OSHA interprets this to mean employees can get to the SDS quickly, without barriers. A binder in a locked office fails this test. A digital system accessible from a phone on the shop floor passes it.

For more on SDS requirements, see [What Is a Safety Data Sheet (SDS)?](/blog/what-is-sds)

4. Container Labeling Procedures

Your program must describe:

• How incoming containers are verified — who checks that manufacturer labels are intact and GHS-compliant
• How secondary containers are labeled — the process and materials used for labeling containers when chemicals are transferred (spray bottles, buckets, pour containers)
• What label system you use — pre-printed labels, handwritten labels, label makers, or a combination
• Exemptions — when immediate-use containers don't require labels (employee who transferred the chemical uses it entirely within the same shift and doesn't leave the area)

Secondary container labeling is one of the most frequently cited HazCom violations. Your program needs to explicitly address it. For the full breakdown of what goes on a label, see [GHS Label Requirements: What OSHA Expects on Every Container](/blog/ghs-label-requirements-osha).

5. Employee Training Plan

Your program must describe:

• When initial training occurs — before an employee works with or near hazardous chemicals (not "within 30 days")
• What topics training covers:
• When retraining occurs — when new chemicals are introduced, processes change, or the standard is updated
• How training is documented — what records are kept (date, topics, trainer, attendees)

Generic training that doesn't reference the actual chemicals at your site is a common weak point. OSHA expects training to be specific to the hazards in each employee's work area — not a one-size-fits-all video.

6. Non-Routine Task Procedures

Your program must address how chemical hazards are managed during tasks that employees don't perform regularly. Examples:

• Cleaning a storage tank that normally doesn't require entry
• Handling a chemical spill in an area where chemicals aren't usually present
• Performing maintenance on equipment that contains hazardous materials
• One-time projects involving unfamiliar chemicals

For each type of non-routine task, describe:

• How employees are informed of the chemical hazards they may encounter
• What additional protective measures are required
• Who authorizes the task and verifies safety precautions

This is one of the most overlooked sections. Many businesses write a thorough program for daily operations but forget about the once-a-year tasks that can be the most dangerous.

7. Multi-Employer Workplace Coordination

If contractors, temporary workers, or employees from other companies work at your site, your program must describe:

• How you inform outside workers about chemical hazards they may encounter at your site
• How you provide access to relevant SDSs and your chemical inventory
• How you share emergency procedures — evacuation routes, spill response, emergency contacts
• How you receive information about hazardous chemicals that contractors bring onto your site

This section applies to construction sites, facilities with regular contractor work, businesses that use temporary staffing agencies, and any shared workspace where multiple employers' employees are present.

Common Mistakes That Get Programs Cited

The Generic Template

Downloading a template and filling in your company name is not a written HazCom program. OSHA inspectors can spot a generic template immediately because:

• It references chemicals that don't match what's on your shelves
• It describes procedures that don't match what your employees actually do
• It hasn't been updated for HazCom 2024 changes

Your program must reflect your actual workplace, your actual chemicals, and your actual procedures.

The "Set It and Forget It" Program

A written program from 2019 that hasn't been reviewed since is a liability. Your program needs to be a living document that gets updated when:

• New chemicals are added to the workplace
• Employees change roles or new employees are hired
• Procedures change (e.g., switching from paper SDSs to digital)
• Regulations change (e.g., [HazCom 2024 updates](/blog/osha-hazcom-2024-small-business-guide))
• Your facility layout changes

Best practice: review your written program at least annually and update it immediately when significant changes occur.

Missing the Non-Routine Tasks Section

Most programs cover the daily operations well but completely skip non-routine tasks. OSHA specifically requires this section, and inspectors know to look for it.

No Multi-Employer Provisions

If you have any contractors or outside workers at your facility — even occasionally — and your program doesn't address how you share hazard information with them, that's a gap.

What an OSHA Inspection Looks Like

When an OSHA compliance officer conducts a HazCom inspection, here's what happens with your written program:

1. They ask to see it. If you can't produce it promptly, that's already a problem.
2. They read it. They're checking that all required elements are covered.
3. They compare it to reality. Does your program say SDSs are in a binder in the break room? They'll go check. Does it say the Safety Manager handles training? They'll ask that person about training records.
4. They look for specificity. Generic language like "appropriate measures will be taken" gets flagged. They want to see specific procedures, specific chemicals, specific people.
5. They check the date. When was the program last reviewed? If it pre-dates HazCom 2024, it needs updating.

How to Write Your Program: Step by Step

Step 1: Start with your chemical inventory. You can't write a meaningful program without knowing what chemicals you have.

Step 2: Walk your facility. Observe how chemicals are actually handled — receiving, storage, use, transfer to secondary containers, disposal. Your program must describe what actually happens, not what should happen in theory.

Step 3: Write each of the 7 sections above, referencing your specific chemicals, locations, and people.

Step 4: Address HazCom 2024 updates. If your program was written before the 2024 rule, update it to reference the new hazard categories, updated SDS requirements, and revised labeling provisions.

Step 5: Have the responsible person (Safety Manager, owner, EHS coordinator) review and sign the document.

Step 6: Make the program accessible. Employees need to know where to find it. Keep copies at each worksite — physical or digital.

Step 7: Schedule your next review. Put it on the calendar. Annual reviews at minimum, plus ad-hoc updates when things change.

Digital vs. Paper Programs

A written HazCom program doesn't have to be a physical document — "written" means documented, not printed. Digital programs have several advantages:

• Easier to update when chemicals or procedures change
• Accessible from anywhere — employees can review it on their phone
• Version control — you can see when it was last updated and by whom
• Connected to your inventory — the chemical list in your program stays in sync with your actual inventory automatically
• Audit trail — timestamped records of who accessed or updated the program

Whether you use a paper document, a shared drive, or a compliance platform, the content requirements are the same. The format is your choice — OSHA doesn't mandate paper or digital.

OSHA Penalties for Written Program Violations

A missing or deficient written program is typically cited as a single violation — but it's often found alongside other HazCom violations (missing SDSs, incomplete training, unlabeled containers) that multiply the total penalty. Use our [OSHA HazCom compliance checklist](/blog/osha-compliance-checklist) to check your full compliance posture.

Key Takeaways

• Every employer using hazardous chemicals must have a written HazCom program — no exceptions
• 7 required elements: scope/responsibilities, chemical inventory, SDS management, labeling, training, non-routine tasks, and multi-employer coordination
• Specificity matters — generic templates don't pass inspection. Your program must describe your workplace, your chemicals, your procedures
• Keep it current — review annually at minimum. Update immediately when chemicals, procedures, or regulations change
• Make it accessible — employees need to know where to find it and be able to access it during any shift
• Non-routine tasks and contractor coordination are the two most commonly overlooked sections — don't skip them