The 5 Things OSHA Requires in Every HazCom Program (Plain English, No Legalese)

HazCom Doesn't Have to Be Complicated

If you've ever tried reading OSHA's Hazard Communication Standard — the actual regulation at 29 CFR 1910.1200 — you probably gave up around paragraph (c)(5)(iv)(B)(2). It reads like it was written by lawyers for lawyers, because it was.

But the actual requirements? They're not complicated. There are five things OSHA wants you to do. Five. That's it.

The problem is that most businesses either don't know what those five things are, or they know vaguely but aren't sure if they're doing them right. So they end up doing nothing — or doing a half-version that falls apart during an inspection.

This article breaks down each requirement in plain English. No legal citations (okay, a few — but only where they matter). No jargon. Just what you need to do and what counts as doing it.

Quick Overview: The 5 Requirements

Before we dive deep, here's the cheat sheet:

Now let's break each one down.

Requirement 1: The Written Program

What the regulation says: 29 CFR 1910.1200(e) — you need a written hazard communication program.

What that actually means: You need a document — physical or digital — that explains how your company handles chemical safety. Not a poster on the wall. Not a mental note. A written program that someone can pick up, read, and understand.

What goes in it:

• Who's in charge of your chemical safety program (an actual name or job title, not "management")
• How you keep track of your chemicals (your inventory process)
• How you manage SDSs (where they are, how employees access them, how you get new ones)
• How you handle labeling (who checks labels, what happens when one falls off)
• How you train employees (when, who trains them, what's covered)
• How you deal with contractors (sharing chemical info when other companies work at your site)
• How you handle non-routine tasks (one-off jobs that involve chemicals, like cleaning a tank)

What counts:

• A Word document that's specific to your workplace and gets updated when things change
• A program generated from your actual chemical inventory in a system like Tellus EHS
• A detailed document available to every employee, not locked in a manager's drawer

What doesn't count:

• A generic template you downloaded from the internet five years ago with "[COMPANY NAME]" still in the header
• A verbal understanding that "everyone knows the chemicals"
• A beautiful document that describes a program you don't actually follow

The most common mistake:

Having a written program that doesn't match reality. OSHA inspectors don't just read the document — they walk the floor. If your program says SDSs are in a binder in the break room and the inspector finds no binder in the break room, that's a violation. If your program says employees are trained quarterly and there are no training records, that's a violation.

For a detailed breakdown and template, see our guide to HazCom written program requirements.

Requirement 2: Safety Data Sheets (SDSs) for Every Chemical

What the regulation says: 29 CFR 1910.1200(g) — you must maintain an SDS for each hazardous chemical and make them accessible to employees during their work shift.

What that actually means: Every hazardous chemical in your workplace needs a 16-section document that explains what the chemical is, what it can do to you, and how to handle it safely. And your employees need to be able to get to those documents whenever they need them.

What goes in an SDS:

You don't write SDSs — the chemical manufacturer does. Each SDS follows a standardized 16-section format (required by the Globally Harmonized System, or GHS). The key sections for everyday use are:

• Section 2: What hazards the chemical has (this is the "danger" summary)
• Section 4: What to do if someone gets exposed (first aid)
• Section 7: How to safely handle and store the chemical
• Section 8: What protective equipment to use

For the full breakdown, see our guide on what an SDS is and how to read one.

What counts:

• An SDS on file for every hazardous chemical at your worksite — no exceptions
• SDSs that are current (manufacturers update them; your 2015 SDS for a reformulated product won't cut it)
• SDSs that employees can actually access during their shift — per 29 CFR 1910.1200(g)(8), they must be "readily accessible during each work shift"

What doesn't count:

• An SDS binder in a locked office when workers are on the shop floor
• SDSs for chemicals you used to have but not for the ones you have now
• A shared drive that employees don't have login credentials for
• "We can look it up on Google" — OSHA expects you to have them on hand, not to search for them in an emergency

The most common mistakes:

1. Missing SDSs — You have 47 chemicals but only 30 SDSs. The inspector will count.
2. Outdated SDSs — The manufacturer updated the SDS in 2024 but you still have the 2018 version. Manufacturers are required to update SDSs when new hazard information becomes available. You should be checking for updates.
3. Inaccessible SDSs — "Accessible" means accessible to the people who work with the chemicals, not accessible to the safety manager. Second shift workers need access too. So do employees who don't sit at computers.
4. No process for new chemicals — A new product shows up on Monday and gets used on Tuesday with no SDS. This is one of the easiest things to fix and one of the most common violations.

Requirement 3: Labels on Every Container

What the regulation says: 29 CFR 1910.1200(f) — every container of a hazardous chemical must be labeled.

What that actually means: Every container — from the 55-gallon drum to the spray bottle — needs a label that tells workers what's inside and what dangers it poses. There are two types of labels to worry about.

Manufacturer Labels (the ones that come on the container)

When a chemical arrives at your workplace, it should already have a GHS-compliant label from the manufacturer. This label must include:

• Product identifier (the chemical name)
• Signal word ("Danger" or "Warning")
• Hazard statement(s) (what the chemical can do — "causes skin burns," "may cause cancer")
• Pictogram(s) (those red-bordered diamond symbols)
• Precautionary statement(s) (how to handle it safely)
• Supplier identification (name, address, phone number)

Your job: don't remove or deface these labels. That's it. If a manufacturer label gets damaged or becomes illegible, replace it with one that has the same information.

Workplace Labels (the ones you create)

When an employee transfers a chemical from the original container to a smaller container — say, pouring a cleaning solution into a spray bottle — that secondary container needs a label too.

Workplace labels must include at minimum:

• Product identifier (what's in the container)
• Words, pictures, symbols, or a combination that provide general information about the chemical's hazards

That second part is intentionally flexible. You can use the full GHS label elements, or you can use a simpler system — as long as employees can identify the chemical and its hazards. Many workplaces use simplified labels with the product name and the relevant pictograms.

The one exception:

A portable container intended for immediate use by the employee who transferred the chemical doesn't need a label — per 29 CFR 1910.1200(f)(8). But "immediate use" means the employee fills the container, uses it during that same work session, and doesn't leave it sitting around. The moment that spray bottle sits on a shelf overnight, it needs a label.

The most common mistakes:

1. Unlabeled spray bottles — This is the #1 labeling violation in small businesses. Employees pour chemicals into unmarked bottles "because they know what it is." Then they go on vacation and someone else picks it up.
2. Stretching "immediate use" — If you refill containers at the start of the shift and use them all day, that's not immediate use. Label them.
3. Faded or damaged labels — Labels on drums stored outside or near chemicals deteriorate. If you can't read it, it doesn't count.
4. Missing pictograms — The red-bordered diamonds aren't decoration. They're required hazard communication elements.

For the full scoop on labeling, see our GHS label requirements guide.

Requirement 4: Employee Training

What the regulation says: 29 CFR 1910.1200(h) — employees must be trained on chemical hazards at the time of their initial assignment and whenever a new chemical hazard is introduced.

What that actually means: Before your employees work with or around hazardous chemicals, you have to teach them what those chemicals are, what they can do, and how to protect themselves. And you have to be able to prove you did it.

What training must cover:

OSHA specifies that training must include:

• The requirements of the HazCom standard — employees should know the standard exists and what their rights are
• Operations in their work area where hazardous chemicals are present — not a general overview, but the specific chemicals in their specific work area
• Location of the written program, chemical inventory, and SDSs — they need to know where to find information
• How to read an SDS and a label — the 16 sections, the pictograms, the signal words
• Physical and health hazards of the chemicals — what can burn them, poison them, make them sick
• Protective measures — PPE, safe handling procedures, what to do in an emergency

When training must happen:

• Before initial assignment — new hires must be trained before they start working with chemicals. Not during their first week. Before.
• When new hazards are introduced — new chemical? New process? Employees need to know.
• OSHA doesn't require annual refreshers in the standard text, but most safety professionals (and many state plans) recommend or require them. It's smart practice regardless.

What counts as proof:

• Sign-in sheets with date, employee name, topics covered, and trainer name
• Training records maintained in a system (digital or paper)
• Quiz or assessment results showing comprehension
• Training completion certificates

What doesn't count:

• "We told them about it at the staff meeting" — with no documentation
• A generic safety video with no record of who watched it
• Training that covers "workplace safety" broadly but never mentions specific chemicals
• Having the written program available but never actually walking employees through it

The most common mistakes:

1. No documentation — You may have trained everyone. But if you can't prove it, OSHA treats it as if you didn't.
2. Generic training — The warehouse team and the office staff have different chemical exposures. Training should be specific to each work area.
3. Forgetting new hires — Three months in and still no HazCom training. That's a violation from day one.
4. No retraining for new chemicals — You added a new degreaser last month but only told the purchasing manager.

Requirement 5: A Complete List of Hazardous Chemicals

What the regulation says: 29 CFR 1910.1200(e)(1)(i) — your written program must include a list of the hazardous chemicals known to be present at each worksite.

What that actually means: You need an inventory — a complete, up-to-date list of every hazardous chemical at each work location. This is the foundation that everything else builds on.

What the list should include:

At minimum: - Product name (matching what's on the SDS and the container label) - Manufacturer or supplier - Location where it's used or stored

Best practice additions: - Quantity on hand - SDS availability status (do you have a current SDS for this product?) - Date added to the inventory - Department or area

What counts as a "hazardous chemical":

This is broader than you think. It's not just the skull-and-crossbones stuff. A hazardous chemical is any chemical that poses a physical hazard (fire, explosion, reactivity) or health hazard (irritation, sensitization, organ damage, cancer, reproductive effects).

That includes: - Industrial solvents and degreasers - Paints, coatings, and adhesives - Cleaning products (yes, even the "green" ones if they have an SDS) - Compressed gases - Fuels and lubricants - Welding materials - Pesticides and herbicides - Concrete additives - Battery acid

If the manufacturer provides an SDS for it, it belongs on your list.

What doesn't need to be listed:

• Consumer products used in the same manner and quantity as a typical consumer (the hand soap in the bathroom, for example)
• Food and beverages for employee consumption
• Pharmaceuticals dispensed in final form
• Products covered by other specific regulations (hazardous waste, tobacco, etc.)

The most common mistakes:

1. Incomplete inventories — You listed the chemicals in the production area but forgot the maintenance closet, the break room cleaning supplies, the products in the loading dock, and the chemicals in the company vehicles.
2. Stale lists — The inventory was accurate two years ago. Since then, you've added 12 new products and stopped using 8 others, but the list never changed.
3. Name mismatches — Your inventory says "All-Purpose Cleaner" but the SDS says "ZEP Heavy-Duty Citrus Degreaser." The inspector will notice.
4. No process for updates — Nobody owns the chemical inventory. Products arrive and get used without ever appearing on the list.

How These 5 Requirements Work Together

These aren't five independent checkboxes. They're a system, and they connect:

• Your chemical list (Requirement 5) drives everything else
• You need an SDS (Requirement 2) for every chemical on that list
• Every chemical needs a label (Requirement 3) on its container
• Employees need training (Requirement 4) on the chemicals they work with
• Your written program (Requirement 1) describes how you do all of the above

When one piece falls behind, the others follow. An outdated chemical list means missing SDSs, which means incomplete training, which means your written program doesn't match reality.

This is why managing HazCom with disconnected tools — a spreadsheet here, a binder there, training records in an email folder — eventually breaks down. The pieces aren't connected, so they drift apart.

The Penalty for Getting It Wrong

HazCom is consistently one of OSHA's top 10 most-cited standards every year. Penalties as of 2025:

• Serious violation: Up to $16,550 per violation
• Willful or repeat violation: Up to $165,514 per violation
• Failure to abate: Up to $16,550 per day past the abatement deadline

And remember: HazCom violations rarely come alone. An inspector who finds one problem usually finds several. No written program + missing SDSs + no training records = three separate violations.

For a complete inspection prep checklist, see our OSHA compliance checklist.

Keep It Simple. Keep It Connected.

The five requirements aren't hard. What's hard is keeping them current, connected, and accessible across your team — especially when you're running a business and HazCom is nobody's full-time job.

That's the problem Tellus EHS was built to solve. You add your chemicals. Tellus manages your SDS library, generates your written program, tracks your training, and keeps your inventory current — all in one place, accessible from any device.

No binder. No spreadsheet. No "I'll update it next month."

Start your 14-day free trial at tellusehs.com. Plans start at $99/month. Five requirements, one system.