How to Build a HazCom Program from Scratch (Step-by-Step for Small Businesses)

You just realized you need a HazCom program. Maybe OSHA sent a letter. Maybe a client asked for it. Maybe you Googled "do I need a chemical safety program" and the answer was an uncomfortable yes.

Whatever brought you here, the situation is the same: you have chemicals in your workplace, no formal program, and no idea where to start.

Good news — building a HazCom program isn't rocket science. It's methodical. It takes effort, not expertise. And this guide will walk you through every single step, from "I have nothing" to "I'd hand this to an OSHA inspector without flinching."

Let's build this thing.

Before You Start: What a HazCom Program Actually Is

OSHA's Hazard Communication Standard (29 CFR 1910.1200) requires every employer with hazardous chemicals to do six things:

1. Maintain a written HazCom program
2. Keep a chemical inventory
3. Have a Safety Data Sheet for every chemical
4. Label every container
5. Train employees
6. Make everything accessible to workers

That's it. Six elements. The standard has been around since 1983. It's not ambiguous and it's not optional. HazCom ranks as one of OSHA's top 10 most-cited standards every single year, with penalties starting at $16,550 per serious violation and climbing to $165,514 for willful or repeat violations.

Now let's build each piece.

Step 1: Inventory Every Chemical in Your Workplace

This is the foundation. Everything else — your SDS collection, your labels, your training program — depends on knowing exactly what chemicals you have. Skip this step or do it halfway, and the rest of your program is built on sand.

How to Do the Chemical Walk-Through

Grab a clipboard (or your phone) and physically walk through your entire facility. Every room. Every closet. Every cabinet. You're looking for anything that has a chemical label, an SDS, or could reasonably be classified as a hazardous chemical.

Here's what people miss:

• Under sinks — cleaning supplies, degreasers, drain openers
• Break rooms — oven cleaners, sanitizers, dishwashing chemicals
• Maintenance closets — lubricants, WD-40, adhesives, paints
• Offices — toner cartridges, whiteboard cleaners, compressed air cans
• Loading docks — fuels, de-icers, equipment fluids
• Vehicles — if company vehicles store chemicals (windshield washer fluid, starting fluid, fuel treatments)
• Outdoor storage — propane tanks, pesticides, fertilizers
• Personal items — that can of bug spray someone keeps in their desk? If it's in the workplace, it counts

What to Record

For each chemical, capture:

Don't overthink formatting. A spreadsheet works. A notepad works. The point is completeness, not elegance.

The "Is This Actually a Chemical?" Question

If you're unsure whether something counts as a hazardous chemical under HazCom, check the label. If it has hazard pictograms, signal words (Danger or Warning), or hazard statements, it's covered. If there's an SDS available for it, it's covered.

Common items people don't realize are covered:

• Hand sanitizer (contains ethanol — flammable)
• Correction fluid (White-Out)
• Certain printer toners
• Super Glue (cyanoacrylate)
• Dry-erase markers (solvents)

When in doubt, include it. Nobody has ever been cited for having too thorough an inventory.

How Many Chemicals Should You Expect?

Most small businesses are surprised by the count:

• Office-only business: 5-15 chemicals
• Auto repair shop: 30-80 chemicals
• Small manufacturer: 50-200+ chemicals
• Restaurant: 10-25 chemicals
• Construction subcontractor: 20-60 chemicals

If your count seems low, you probably missed something. Walk through again.

Step 2: Collect a Safety Data Sheet (SDS) for Every Chemical

Once you know what chemicals you have, you need a Safety Data Sheet for each one. An SDS is a standardized 16-section document that tells you everything about a chemical — what's in it, what hazards it poses, how to handle it safely, and what to do if something goes wrong.

Where to Get Safety Data Sheets

Under OSHA 29 CFR 1910.1200(g)(1), chemical manufacturers and importers are required to provide SDS to downstream users. Here's how to actually get them:

1. Manufacturer's website — Most major manufacturers have SDS libraries on their websites. Search "[manufacturer name] SDS" and you'll usually find a searchable database.

2. Distributor — Whoever sold you the chemical is required to provide the SDS. Call or email them.

3. Contact the manufacturer directly — If the website doesn't have it, call the phone number on the product label. They're legally obligated to provide it.

4. SDS aggregator sites — Sites like SafetyDataSheets.com or the manufacturer's own portals can help, but always verify the SDS matches your exact product (same product name, same manufacturer).

What to Check on Every SDS

When you receive an SDS, verify:

• It matches your product — same product name, same manufacturer. A "close enough" SDS for a similar product from a different brand won't pass inspection.
• It's current — SDS should be updated when new health/safety information becomes available. An SDS from 2008 for a product you bought last month is a red flag.
• It has all 16 sections — The GHS-aligned format requires 16 specific sections. If it's missing sections or uses an old format (the pre-2012 MSDS format with 8 sections), request an updated version.
• It's in English — If your workforce needs other languages, you'll want translations too, but English is the OSHA baseline.

Organizing Your SDS Collection

You need to organize your SDS so employees can find any sheet during any shift without asking for help. That's the "readily accessible" requirement in 29 CFR 1910.1200(g)(8).

Options:

• Physical binder — Alphabetical by product name, with a table of contents. Keep it in a common area, not a locked office. Works for small operations.
• Shared drive/folder — Digital SDS accessible from a computer. Make sure the computer is available and workers know how to search.
• SDS software — A platform that stores, organizes, and lets workers search SDS from any device. Faster to set up and easier to maintain than binders.

The binder approach works until it doesn't. Binders get disorganized. Pages fall out. Nobody updates them. If you have more than 20 chemicals, seriously consider going digital from the start.

Step 3: Label Every Container (Including Secondary Containers)

OSHA requires that every container of hazardous chemicals in your workplace is labeled. This applies to the original manufacturer's container and — this is the part people miss — every secondary container too.

Original Container Labels

Containers from the manufacturer must have GHS-compliant labels that include:

• Product identifier (name that matches the SDS)
• Signal word (Danger or Warning)
• Hazard statement(s) describing the nature of the hazard
• Pictogram(s) — the red-bordered diamond symbols
• Precautionary statements — prevention, response, storage, disposal
• Supplier identification — name, address, phone number

If a container arrives without a proper label, don't put it into use until you get one. Under 29 CFR 1910.1200(f)(9), the employer must ensure labels are not removed or defaced.

Secondary Container Labels — Where Most Violations Happen

A secondary container is anything that isn't the original manufacturer's container. Spray bottles filled from a bulk container. Small cups for application. Parts washer basins. The bucket you mixed something in.

Under 29 CFR 1910.1200(f)(6), secondary containers must be labeled with:

• The product identifier (matching the SDS)
• Words, pictures, symbols, or a combination that provide the same hazard information as the manufacturer's label

The only exception: if the secondary container is for immediate use by the employee who transferred it, and that employee maintains control of it during their entire shift. The moment it could sit on a shelf and someone else could encounter it, it needs a label.

This is one of the most common HazCom violations OSHA cites. The unlabeled spray bottle is practically a cliche at this point.

Practical Labeling Tips

• Buy pre-printed GHS labels — Available for common chemicals (bleach solutions, degreasers, etc.) from safety supply companies. A few dollars per sheet.
• Use a label maker with GHS templates — If you have many secondary containers, a dedicated label printer pays for itself in an afternoon.
• Waterproof labels — Regular paper labels dissolve in wet environments. Spend the extra dollar on synthetic or laminated labels.
• Check labels regularly — Labels fade, peel, and get splashed with chemicals. A label you can't read isn't a label.

Step 4: Write the HazCom Program Document

This is the part that intimidates people the most. It shouldn't. The written HazCom program is a document — not a binder, not a library, not a system. A document. It describes how your company implements each piece of the Hazard Communication Standard.

OSHA spells out what it must contain in 29 CFR 1910.1200(e):

Required Contents

1. Chemical inventory management Describe how you maintain your list of hazardous chemicals. How often is it updated? Who is responsible? Where is the list kept?

2. SDS management How do you obtain SDS for new chemicals? Where are they stored? How do employees access them? What happens when an SDS is missing?

3. Labeling procedures Who is responsible for labeling? How are secondary containers labeled? What happens when a label is damaged or missing?

4. Employee training When are employees trained? (At hiring, when new chemicals are introduced, annually?) Who conducts training? What does training cover?

5. Non-routine tasks How do you handle situations where employees perform tasks outside their normal routine that involve chemical exposure? (Example: cleaning out a storage tank, painting a room, handling a spill.)

6. Multi-employer workplace coordination If contractors, temporary workers, or other employers' employees work at your site, how do you share chemical hazard information with them? How do they share theirs with you?

7. Program administration Who is responsible for the overall program? Name a specific person or role — not "management." Include the date the program was last reviewed and updated.

Writing Tips

• Be specific to your workplace. A generic template downloaded from the internet won't pass inspection. OSHA wants to see that this document describes *your* operations, *your* chemicals, *your* people.
• Use plain language. Nobody is grading your prose. Write it so your newest employee can understand it.
• Keep it honest. If you update your inventory quarterly, don't write "monthly." Inspectors will check.
• Date it. Include the date of the last review. Review it at least annually.
• It doesn't need to be long. For a small business, 3-5 pages is plenty. For a larger operation, 8-15 pages. This is not a novel.

Common Mistakes in Written Programs

• Using a template with another company's name still in it (yes, this happens)
• Not naming a responsible person
• Saying SDS are "available upon request" instead of "readily accessible"
• Forgetting the non-routine tasks section
• Forgetting the multi-employer coordination section
• Never updating it after the initial creation

Step 5: Train Your Employees

Training is where the rubber meets the road. You can have a perfect inventory, every SDS organized, every container labeled — but if your employees don't know what any of it means, the program fails.

What OSHA Requires in HazCom Training

Under 29 CFR 1910.1200(h), training must cover:

1. The requirements of the HazCom standard itself — employees need to know this standard exists and what it requires
2. Operations in their work area where hazardous chemicals are present — what chemicals they'll encounter in their specific job
3. Where the chemical inventory and SDS are located and how to access them
4. How to read an SDS — what each section means and how to find critical information (hazards, first aid, PPE requirements)
5. How to read container labels — understanding GHS pictograms, signal words, and hazard statements
6. Physical and health hazards of the chemicals in their work area
7. How to protect themselves — PPE requirements, safe handling procedures, what to do in a spill or exposure
8. How to detect the presence or release of a hazardous chemical (visual appearance, odor, monitoring devices)

When to Train

• At hiring — before the employee starts working with or near chemicals
• When a new chemical is introduced to the workplace
• When a new hazard is identified about an existing chemical
• Refresher training — OSHA doesn't specify a frequency for HazCom refreshers, but annual refreshers are best practice and many states require them

Training That Actually Works

Let's be honest — nobody remembers a 90-minute PowerPoint. Make your training stick:

• Keep it relevant. Don't train the office staff on the same chemicals as the shop floor crew. Customize by work area.
• Use the actual chemicals. Walk employees through the chemicals they'll handle. Show them the labels. Pull up the SDS.
• Make it interactive. Have employees locate the SDS binder or system. Have them read a label. Quiz them on pictograms.
• Keep it short enough to retain. 30-45 minutes is the sweet spot for initial training. Refreshers can be 15-20 minutes.
• Translate if needed. If employees are more comfortable in another language, provide training materials in that language. OSHA doesn't require it, but comprehension is the point.

Document Everything

For every training session, record:

• Date of training
• Topics covered
• Names and signatures of attendees
• Name of the trainer
• Materials used

Keep these records. OSHA will ask for them. There's no specified retention period for HazCom training records, but best practice is to keep them for at least 3-5 years and for the duration of employment.

Step 6: Make Everything Accessible

"Readily accessible" is the phrase OSHA uses, and they mean it literally. Employees must be able to access the following during every work shift without needing to ask anyone for permission:

• The written HazCom program
• The chemical inventory
• Safety Data Sheets for every chemical in their work area

What "Readily Accessible" Means in Practice

• A binder in an unlocked common area near the work area — passes
• A binder in the manager's locked office — fails
• A shared computer with SDS files in a searchable folder — passes (if the computer is always available and workers know how to use it)
• SDS "available upon request from the safety manager" — fails. Employees can't be required to ask anyone.
• A mobile-friendly digital platform accessible from phones — passes, and it's increasingly what OSHA expects

For multi-shift operations, accessibility has to work at 2 AM the same way it works at 10 AM. If your SDS binder is in a room that gets locked after the day shift leaves, you've got a problem.

The Night Shift Test

Here's a good gut check: if an employee on the night shift, working alone, needed to look up first-aid procedures for a chemical splash, could they do it right now? Without calling anyone? Without waiting for a manager?

If the answer is no, your program has a gap.

Step 7: Keep It Updated

A HazCom program isn't a one-time project. It's a living system. Chemicals get added, products get reformulated, employees turn over. Your program has to keep up.

What Triggers an Update

Build a Review Cadence

• Monthly: Quick check — any new chemicals added? Any SDS requests outstanding?
• Quarterly: Inventory spot-check — walk a section of the facility and compare what's on shelves to what's on the list
• Annually: Full program review — update the written program, verify all SDS are current, review training records, check all labels

The #1 Reason Programs Fall Apart

It's not complexity. It's not cost. It's that nobody owns it.

If "everyone" is responsible for the HazCom program, nobody is. Assign one person. Put their name in the written program. Make it part of their job description. Give them time to actually do it.

For a small business, this might be 2-4 hours per month. For a larger operation, it could be a part-time or full-time role. Either way, it has to be someone's job — not everyone's afterthought.

The Complete Checklist

Here's your build checklist. Print it out, work through it, check things off.

• [ ] Walk through every area of the facility and list every chemical
• [ ] Record product name, manufacturer, location, and quantity for each
• [ ] Collect an SDS for every chemical on the inventory
• [ ] Verify each SDS matches the product (name, manufacturer, current version)
• [ ] Organize SDS so employees can search and find any sheet
• [ ] Check every container for a proper label
• [ ] Label all secondary containers with product identifier and hazard info
• [ ] Write the HazCom program document with all 7 required elements
• [ ] Name a specific person responsible for the program
• [ ] Train all current employees on chemical hazards, SDS, labels
• [ ] Document training with dates, topics, and attendee signatures
• [ ] Verify employees can access SDS, inventory, and the written program during every shift
• [ ] Set up a schedule for monthly, quarterly, and annual reviews
• [ ] Store a copy of the written program where employees can access it

How Long Does This Take?

Realistic timelines for a small business doing this part-time:

The inventory and SDS collection eat most of the time. Tracking down SDS from manufacturers who don't have them easily available is where people get stuck.

DIY vs. Software: An Honest Comparison

You can absolutely build a HazCom program with spreadsheets, a physical binder, and a Word document. Thousands of businesses do. But here's what that approach looks like over time:

DIY (spreadsheets + binders): - Zero cost to start - SDS collection is manual and time-consuming - Binders get outdated as pages fall out or new chemicals arrive - Inventory updates require discipline nobody has - No automated reminders when SDS expire or training is due - Works if you have 10-20 chemicals and a dedicated person

Software (like Tellus EHS): - Chemical inventory with search and filtering - SDS library with automatic retrieval — paste the product name, get the SDS - Label generation for secondary containers - Training tracking with due-date reminders - The written program references a system that actually stays current - Employees access everything from their phone

Neither approach is wrong. The question is whether you trust yourself to maintain a binder for the next five years. If the answer is "probably not," software pays for itself in avoided violations alone.

You Don't Need Permission to Start

Here's the thing nobody tells you about building a HazCom program: you don't need to be a safety professional. You don't need a certification. You don't need to hire a consultant (though they can help).

You need a list of chemicals, an SDS for each one, labels on containers, a document describing your program, and trained employees.

That's it. It's not glamorous. It won't win awards. But it will keep you compliant, keep your workers informed, and keep you out of OSHA's crosshairs.

Start with Step 1. Walk through your facility with a clipboard. Write down every chemical you find. Everything else flows from there.

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Ready to stop managing chemical safety with binders and spreadsheets? Tellus EHS helps small businesses build a complete HazCom program — chemical inventory, SDS management, labeling, and training tracking — in one platform. Start your 14-day free trial (no credit card required) and see how fast you can go from zero to compliant. Plans start at $99/month.