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OSHA HazCom Compliance Checklist: 10 Steps to Get Audit-Ready

Tellus EHS Team·

Why You Need a HazCom Compliance Checklist

OSHA inspections can happen with little or no warning. When an inspector arrives, you need to demonstrate that your Hazard Communication program is complete, current, and well-documented. This checklist covers the essential elements that inspectors look for.

The 10-Step Compliance Checklist

1. Written HazCom Program

Your written program is the foundation. Make sure it:

  • Is specific to your workplace (not a generic template)
  • Lists all worksites and departments covered
  • Describes how you manage SDSs, labels, and training
  • Addresses non-routine tasks and contractor communication
  • Has been reviewed and updated within the past year

2. Complete Chemical Inventory

Maintain an up-to-date list of every hazardous chemical at each worksite:

  • Include chemical name, manufacturer, and location
  • Update the list when chemicals are added or removed
  • Cross-reference with your SDS collection
  • Account for chemicals in all areas (maintenance closets, break rooms, loading docks)

3. Safety Data Sheet Collection

For every chemical on your inventory list:

  • Have a current SDS on file (not older than 3 years without verification)
  • Ensure SDSs are in the GHS 16-section format
  • Make SDSs accessible to employees during every shift
  • Have a process for obtaining SDSs for new chemicals before use

4. Container Labeling

Every container of a hazardous chemical must be properly labeled:

  • Original manufacturer labels must remain intact and legible
  • Secondary containers need GHS-compliant labels (product name, hazard info, pictograms)
  • Portable containers for immediate use are the only exception
  • Pipes and process vessels should be labeled or have alternative identification

5. Employee Training Records

Document that every employee has received HazCom training:

  • Initial training before working with or near hazardous chemicals
  • Refresher training when new chemicals or hazards are introduced
  • Records should include date, topics covered, trainer name, and employee signature
  • Keep records for the duration of employment

6. GHS Pictogram Knowledge

Verify that employees can identify and explain:

  • All 9 GHS pictograms and their meanings
  • Signal words (DANGER vs. WARNING)
  • How to locate hazard and precautionary statements on labels
  • Where to find additional information on the SDS

7. Emergency Procedures

Document and train on chemical emergency response:

  • Spill containment and cleanup procedures
  • Emergency contact numbers posted prominently
  • Location of safety showers, eyewash stations, and spill kits
  • Evacuation routes for chemical release scenarios

8. Contractor Communication

If contractors work at your site:

  • Inform them of chemical hazards they may encounter
  • Provide access to relevant SDSs
  • Share your emergency procedures
  • Document the communication

9. Multi-Location Consistency

For businesses with multiple sites:

  • Each site has its own chemical inventory
  • Written programs are site-specific
  • Training is consistent across locations
  • A central system tracks compliance across all sites

10. Annual Program Review

Set a regular schedule for reviewing your HazCom program:

  • Audit chemical inventory for accuracy
  • Verify all SDSs are current
  • Review training records for gaps
  • Update the written program as needed
  • Document the review date and findings

Digital Tools Make Compliance Easier

Managing all of these requirements manually — with paper binders, spreadsheets, and filing cabinets — is time-consuming and error-prone. Digital compliance platforms like Tellus EHS automate much of this work:

  • **Automated SDS management** keeps your library current with AI-powered parsing and updates
  • **Digital chemical inventory** with barcode scanning eliminates manual tracking
  • **Training management** automatically assigns, tracks, and documents employee training
  • **Compliance dashboards** show you exactly where you stand at any moment
  • **Audit-ready reports** generate documentation on demand for OSHA inspections

The Cost of Non-Compliance

OSHA penalties for HazCom violations can be severe:

  • Serious violations: up to $16,131 per violation
  • Willful or repeated violations: up to $161,323 per violation
  • Beyond fines, inadequate HazCom programs put worker health and safety at risk

Investing in a proper compliance system is far less expensive than a single OSHA citation — and infinitely more valuable than the safety of your team.

Next Steps

Use this checklist to audit your current program. For each item you can't check off, create an action item with a deadline. If you're looking for a faster path to compliance, consider a platform like Tellus EHS that handles the heavy lifting so you can focus on running your business.