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ISNetworld HazCom Requirements: What You Need to Pass the Safety Audit

Tellus EHS Team··12 min read

Someone just told you that you need ISNetworld to work on their project. Maybe it was a general contractor, an oil and gas operator, a facility owner, or a procurement department. The conversation probably went something like: "You'll need to be ISN-compliant before we can issue a PO."

And now you're looking at ISNetworld's portal, trying to figure out what any of this means and how to not fail the safety review.

Let's cut through it. This guide focuses specifically on the HazCom (Hazard Communication) piece — what ISNetworld expects, what their reviewers actually look for, and how to pass on the first submission.

What ISNetworld Actually Is

ISNetworld (ISN) is a contractor prequalification and management platform. Large companies — especially in oil and gas, manufacturing, utilities, construction, and mining — use ISN to vet contractors before allowing them on-site.

The idea is straightforward: instead of each hiring client individually auditing every contractor's safety program, ISN does it centrally. You submit your documentation once, ISN reviews it, and your compliance status is visible to any hiring client on the platform.

The problem: most contractors encounter ISN for the first time when a client requires it, which means you're learning the system while simultaneously trying to pass the audit. Under a deadline.

The Cost of ISN Membership

Let's address this upfront because nobody talks about it:

  • Annual subscription: $1,500-$2,000+ per year, depending on company size and number of hiring client connections
  • RAVS reviews: Included in some plans, additional cost in others
  • Your time: This is the real cost. Preparing documentation, uploading files, responding to reviewer comments, and maintaining your account is a significant time investment — especially the first time

ISN is a cost of doing business in many industries. You don't "choose" ISN — your clients require it. That doesn't make it less expensive, but it does make it non-negotiable if you want the work.

How the RAVS Review Works

RAVS stands for Review and Verification Services. It's ISNetworld's documentation review process, and it's where most contractors get stuck.

Here's how it works:

  1. You upload documentation — safety programs, training records, insurance certificates, and other compliance documents into your ISN account
  2. A RAVS reviewer evaluates your documents — trained reviewers compare your documentation against OSHA requirements and your hiring client's specific criteria
  3. Documents are graded — each section (including HazCom) receives a compliance grade
  4. Deficiencies are flagged — you get specific notes about what's missing or non-compliant
  5. You correct and resubmit — the cycle repeats until you achieve compliance

The review process typically takes 5-10 business days per submission. If you fail and resubmit, add another 5-10 days. This is why getting it right the first time matters — multiple review cycles can push you weeks or months past your deadline.

What ISNetworld Requires for HazCom

ISN's HazCom review is based on OSHA's Hazard Communication Standard (29 CFR 1910.1200). The RAVS reviewer is checking that your documentation demonstrates compliance with the standard. Here's exactly what they look for:

1. Written Hazard Communication Program

This is the centerpiece. Your written HazCom program must be:

  • Company-specific — not a generic template with your name pasted on top
  • Current — dated within the last 12 months or showing a recent review date
  • Complete — covering all required elements per 29 CFR 1910.1200(e)

Required elements the reviewer will check for:

  • Chemical inventory procedures — how you maintain your list of hazardous chemicals
  • SDS management — how you obtain, store, and make SDS accessible to employees
  • Container labeling — procedures for original and secondary container labels
  • Employee training — when, what, and how employees are trained
  • Non-routine tasks — how you handle chemical exposure during non-routine work
  • Multi-employer coordination — how you share hazard information with other employers at shared worksites
  • Named responsible person — a specific individual identified as the program administrator

2. Chemical Inventory

RAVS reviewers want to see evidence that you maintain a chemical inventory. This can be:

  • A list of chemicals referenced in or attached to your written program
  • A separate inventory document
  • A statement in your written program describing how the inventory is maintained and where it's located

The inventory doesn't need to be exhaustive in the submission — but your program needs to demonstrate that you have one and that you maintain it.

3. SDS Management Evidence

Your program must describe an SDS management process that meets the "readily accessible" standard. Specifically:

  • Where SDS are stored — physical location, digital system, or both
  • How employees access them — during every work shift, without needing to request them from a supervisor
  • How new SDS are obtained — when a new chemical enters the workplace
  • How missing SDS are handled — what's the procedure if an SDS can't be found

A common fail point: programs that say SDS are "available upon request" or "maintained by the safety manager." Neither meets OSHA's definition of readily accessible. Workers must be able to access SDS independently.

For a detailed understanding of SDS: What Is an SDS? A Complete Guide

4. Training Documentation

This is where many contractors fail. The RAVS reviewer is looking for:

  • Training content — your program must describe what HazCom training covers (chemical hazards, SDS access, label reading, PPE, emergency procedures)
  • Training frequency — when training occurs (at hire, when new chemicals arrive, refresher schedule)
  • Training records — evidence that training has actually been conducted. This typically means:

You may or may not need to upload actual training records depending on your hiring client's requirements. But your written program must clearly describe your training process.

5. Labeling Procedures

Your program must address:

  • How you ensure manufacturer labels remain intact and legible
  • How secondary containers are labeled (product identifier + hazard information)
  • GHS label requirements — signal words, pictograms, hazard statements
  • Who is responsible for labeling and what happens when labels are damaged or missing

6. Multi-Employer Coordination

As a contractor, this section is especially important. Your program must describe:

  • How you inform the host employer about chemicals you bring to their site
  • How you receive information about chemicals already present at the site
  • How your employees are informed about hazards from other contractors' chemicals
  • How SDS for your chemicals are made available to other employers on-site

This section is the whole reason clients ask for your HazCom program. They need to know how chemical safety information flows between their company and yours.

Common Reasons HazCom Sections Fail RAVS Review

Based on what contractors consistently report, here are the top failure reasons:

1. Generic Template Submission

The RAVS reviewer has seen every free template on the internet. If your program reads like a form letter with blanks filled in — or worse, still has "[Insert Company Name]" in it somewhere — it will be flagged as non-specific to your organization.

Fix: Write the program in your own words, describing your actual procedures. Reference your real job titles, locations, and systems.

2. Missing Non-Routine Task Section

This is the most commonly omitted section. Many templates don't include it. Many safety managers don't think about it. RAVS reviewers specifically check for it because it's a regulatory requirement under 29 CFR 1910.1200(e)(1)(ii).

Fix: Add a section describing how employees are informed about chemical hazards before performing non-routine tasks. Include examples relevant to your work (confined space entry, equipment maintenance, spill cleanup).

3. Missing Multi-Employer Section

Same issue as non-routine tasks — often omitted, always checked. As a contractor, this section is arguably the most important one in your program.

Fix: Describe your specific process for sharing hazard information at multi-employer worksites. How do you inform the GC? How do you learn about chemicals already on-site? How do your workers get this information?

4. "Available Upon Request" Language

Any time your program says employees can "request" SDS from a supervisor, manager, or the office, the reviewer will flag it. OSHA requires SDS to be readily accessible during each work shift — no intermediary required.

Fix: Describe a system where employees can independently access SDS. This could be a binder at the job site, a shared drive accessible from a work computer, or a mobile-accessible digital platform.

5. No Evidence of Training

Your program says you train employees. But where's the proof? If you don't describe your documentation process or provide sample training records, the reviewer may flag it as unverifiable.

Fix: Include your training documentation process in the written program. If the hiring client requires training records, upload sample records showing date, topics, attendees, and trainer.

6. Outdated Program

A program with a review date from three or more years ago raises flags. Industries change, chemicals change, and OSHA updates regulations. Your program should show evidence of regular review.

Fix: Review and re-date your program before submitting to ISN. Include a "Last Reviewed" date and a "Next Review Due" date. Annual review is the standard expectation.

7. No Named Responsible Person

"Management is responsible for this program" doesn't cut it. RAVS reviewers look for a specific person or role.

Fix: Name the person by title (and optionally by name) who owns the HazCom program.

How to Pass on the First Submission

Here's your pre-submission checklist:

Before You Upload

  • [ ] Written program is company-specific (not a generic template)
  • [ ] Program covers all six OSHA-required elements plus program administration
  • [ ] A specific person or role is named as program administrator
  • [ ] Program has a current review date (within the last 12 months)
  • [ ] SDS management section describes "readily accessible" access — not "available upon request"
  • [ ] Non-routine task section is present and describes your actual procedures
  • [ ] Multi-employer coordination section describes how you share hazard info with GCs and other employers
  • [ ] Training section describes content, frequency, and documentation method
  • [ ] Chemical inventory is referenced in the program
  • [ ] Labeling procedures cover both original and secondary containers

Document Formatting

  • Upload as a PDF — not a Word doc. PDFs look more professional and can't be accidentally edited
  • Include your company name and logo on the document
  • Include page numbers and a table of contents for programs longer than 5 pages
  • Make sure the document is legible — proper font size, no handwritten edits on a photocopy

After Submission

  • Monitor your ISN account for reviewer comments
  • Respond to deficiency notices quickly — the faster you resubmit, the faster you get through the cycle
  • Keep a copy of everything you submitted so you can reference it when making corrections

Avetta and Veriforce: Similar Platforms, Similar Requirements

ISNetworld isn't the only contractor prequalification platform. Depending on your clients, you may also encounter:

Avetta (formerly PICS Auditing)

Avetta serves a similar function to ISN — contractor prequalification and compliance management. Their review process evaluates many of the same safety documents, including your written HazCom program. The HazCom requirements are nearly identical because they're both based on the same OSHA standard. If you've built a solid program for ISN, it will work for Avetta with minimal modification.

Veriforce

Veriforce focuses heavily on the energy and pipeline sectors. Like ISN and Avetta, they require contractors to demonstrate safety compliance, including HazCom. Their Operator Qualification and safety management requirements may have additional industry-specific elements, but the core HazCom documentation is the same: written program, chemical inventory, SDS management, training, and labeling.

The Good News

A well-built, OSHA-compliant HazCom program works across all three platforms. The underlying requirement is the same — 29 CFR 1910.1200. Build it once, build it right, and you can submit it anywhere.

The Real Cost of Failing

Let's do the math on what a failed RAVS review actually costs:

Direct costs: - ISN membership: $1,500-$2,000+/year - Time spent preparing initial submission: 10-20 hours - Time spent on corrections and resubmissions: 5-15 additional hours - Potential RAVS re-review fees (depending on plan)

Indirect costs: - Delayed project start — if the hiring client won't issue a PO until you're ISN-compliant, every week of review cycles is a week of lost revenue - Lost bid opportunity — some RFPs require ISN compliance at the time of bid submission. If you're not compliant, you can't bid - Reputation — a "non-compliant" status visible to hiring clients is not the first impression you want

And if this is about more than just ISN — if OSHA actually inspects you:

  • Serious violation: Up to $16,550 per violation
  • Willful/repeat violation: Up to $165,514 per violation
  • HazCom violations are often cited as multiple items — no written program, no SDS, no training, no labels — each is a separate potential citation

For a broader view of OSHA compliance requirements, check our OSHA compliance checklist.

Building the Program: DIY vs. Software vs. Consultant

DIY (Spreadsheets + Word Document)

  • Cost: Your time only
  • Time: 15-30 hours to build from scratch
  • Pros: No out-of-pocket cost
  • Cons: Time-intensive, easy to miss requirements, maintaining it long-term is the hard part

Software Platform (Like Tellus EHS)

  • Cost: Starting at $99/month
  • Time: 5-10 hours to set up
  • Pros: Guided program building, automatic SDS retrieval, training tracking, always up-to-date, accessible from any device — which directly addresses the "readily accessible" requirement
  • Cons: Monthly cost

Safety Consultant

  • Cost: $1,500-$5,000+ for program development
  • Time: 1-2 weeks (their time, not yours)
  • Pros: Expert-built program tailored to your company
  • Cons: Expensive, and you still need a system to maintain it after they leave

Most small contractors end up with a hybrid: they build what they can, fix what the RAVS reviewer flags, and eventually move to software when maintaining spreadsheets and binders becomes unsustainable.

Your ISN Submission Game Plan

Here's the step-by-step to get ISN-compliant for HazCom as fast as possible:

Day 1-2: Inventory and program writing - Walk your workspace, list every chemical - Write your HazCom program document, covering all required sections - Name a responsible person, date the program

Day 3-5: SDS and labeling - Collect an SDS for every chemical on your inventory - Label any secondary containers - Organize SDS so they're accessible (digital is strongly recommended)

Day 6-7: Training and documentation - Conduct HazCom training with your employees - Document it: date, topics, attendees, trainer - Prepare training records for upload

Day 8: Submission - Convert everything to PDF - Upload to ISN - Double-check against the pre-submission checklist above

Day 8-18: Wait for review - Monitor for reviewer comments - Prepare to respond quickly to any deficiency notes

If you do this right, you can be through the process in 3-4 weeks. If you submit a sloppy first attempt, multiply that by two or three review cycles.

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