Free OSHA HazCom Program Template (2026 Updated)
Why You Need a Written HazCom Program
Let's get this out of the way: OSHA doesn't care that you "know the chemicals" or that your team "has been doing this for 20 years." If you don't have a written hazard communication program, you're in violation of 29 CFR 1910.1200(e). Full stop.
The written HazCom program is one of the most commonly cited elements during OSHA inspections. Not because it's hard to create — but because most businesses either don't have one, have a generic template they downloaded in 2017, or have one that describes a program they don't actually follow.
Here's the thing OSHA inspectors will tell you: the written program is the first document they ask for. If it doesn't exist or doesn't match reality, the inspection only gets worse from there.
This article gives you a section-by-section template you can use to build your own. But we'll also tell you the truth about templates — and why the best HazCom programs aren't written by hand at all.
What OSHA Actually Requires
The Hazard Communication Standard at 29 CFR 1910.1200(e)(1) states that employers must:
*"Develop, implement, and maintain at each workplace, a written hazard communication program which at least describes how the criteria specified [for labels, safety data sheets, and employee information and training] will be met."*
Breaking that down, your written program must describe:
- How you maintain your list of hazardous chemicals (the inventory)
- How you obtain, maintain, and provide access to Safety Data Sheets
- How you label containers (both manufacturer and workplace containers)
- How you train employees on chemical hazards
- How you handle non-routine tasks involving hazardous chemicals
- How you communicate hazard information to other employers in multi-employer workplaces
It must be workplace-specific. It must be available to employees on request. And it must describe what you actually do — not what you wish you did.
Section-by-Section Template
Below is a complete outline for a written HazCom program. Each section includes what to write, why it matters, and the mistakes that get people cited.
Section 1: Purpose and Scope
What to include: - Statement that this program complies with OSHA's Hazard Communication Standard (29 CFR 1910.1200) - Which worksite(s) the program covers - Which employees are covered (hint: anyone who may be exposed to hazardous chemicals) - The effective date and most recent revision date
Template language:
*This written Hazard Communication Program has been developed for [Company Name] in accordance with OSHA's Hazard Communication Standard, 29 CFR 1910.1200. This program applies to all employees at [address/worksite] who may be exposed to hazardous chemicals during normal work operations or foreseeable emergencies.*
*Effective Date: [Date]*
*Last Revised: [Date]*
Common mistakes: - Listing a single corporate address when you have multiple worksites (each site needs its own program or a clearly multi-site program) - Using language copied from a different company without changing the details - Forgetting to include maintenance, janitorial, and temporary workers
Section 2: Responsibilities
What to include: - The name (or job title) of the person responsible for the overall HazCom program - Who is responsible for maintaining the chemical inventory - Who is responsible for obtaining and maintaining SDSs - Who is responsible for container labeling - Who is responsible for employee training - Who is responsible for reviewing and updating the program
Template language:
*The following individuals are responsible for implementing this Hazard Communication Program:*
*Program Administrator: [Name/Title]*
*Chemical Inventory: [Name/Title]*
*SDS Management: [Name/Title]*
*Container Labeling: [Name/Title]*
*Employee Training: [Name/Title]*
Common mistakes: - Listing "management" instead of a specific person - Naming someone who left the company two years ago - Not assigning responsibility for contractor communication
Section 3: Chemical Inventory (Hazardous Chemical List)
What to include: - Statement that a complete list of hazardous chemicals is maintained at the worksite - Where the list is kept and how employees can access it - How often the list is updated - The process for adding chemicals to the list when new products arrive - The process for removing chemicals when they're no longer used
Template language:
*A complete list of all known hazardous chemicals present at this worksite is maintained by [Name/Title] and is available [location — e.g., in the break room, on the shared drive, in the digital system]. The list includes the product name, manufacturer, and worksite location for each chemical.*
*The chemical inventory is reviewed and updated [frequency — e.g., monthly, quarterly] and whenever a new chemical is brought on-site or an existing chemical is removed.*
*No new hazardous chemical may be introduced to the worksite until it has been added to the inventory, an SDS has been obtained, and affected employees have been notified.*
Common mistakes: - Having a list from 2019 that hasn't been touched since - Not including chemicals in maintenance closets, vehicles, or break rooms - Not cross-referencing the inventory against actual SDSs on file
For a deep dive on managing chemical inventories, see our chemical inventory management guide.
Section 4: Safety Data Sheets (SDS)
What to include: - How SDSs are obtained for new chemicals (who requests them, from where) - How SDSs are organized and stored (binder, digital system, shared drive) - How employees access SDSs during their work shift - What happens when an SDS is missing or outdated - How often the SDS collection is audited against the chemical inventory
Template language:
*A Safety Data Sheet is maintained for every hazardous chemical on the worksite chemical inventory. SDSs are [kept in a binder at X location / stored digitally in X system / accessible via X method].*
*Employees can access SDSs at any time during their work shift by [describe how — e.g., opening the binder in the shop, logging into the digital SDS system, scanning a QR code at the workstation].*
*When a new chemical is purchased, [Name/Title] is responsible for obtaining the SDS from the manufacturer or distributor before the chemical is used. If an SDS cannot be obtained, the chemical will not be used until the SDS is received.*
*The SDS collection is audited against the chemical inventory [frequency] to ensure completeness.*
Common mistakes: - SDSs in a binder in a locked office that employees can't access during their shift - No process for obtaining SDSs when new chemicals arrive - SDSs that are 10+ years old for products that have been reformulated - No backup access plan for electronic/digital systems (OSHA requires this per 29 CFR 1910.1200(g)(8))
Section 5: Container Labeling
What to include: - How manufacturer labels are maintained (who checks, how often) - Procedures for labeling workplace/secondary containers - What information is required on workplace labels - How damaged or illegible labels are replaced - The exception for portable containers for immediate use
Template language:
*All containers of hazardous chemicals received at this worksite must retain the manufacturer's original GHS-compliant label, including the product identifier, signal word, hazard statement(s), pictogram(s), precautionary statement(s), and supplier identification.*
*When chemicals are transferred to secondary or workplace containers, the container must be labeled with at minimum: the product identifier, the appropriate signal word, and the relevant hazard statement(s) or pictogram(s). The only exception is a portable container intended for immediate use by the employee who performed the transfer, per 29 CFR 1910.1200(f)(8).*
*[Name/Title] conducts [frequency] inspections of all container labels to ensure they are legible and intact. Damaged or illegible labels are replaced immediately.*
Common mistakes: - Employees transferring chemicals to spray bottles with no label - "Immediate use" exception being stretched to mean "we'll label it eventually" - Not inspecting labels regularly — ink fades, labels peel, chemicals get splashed on them
Section 6: Employee Training
What to include: - When training occurs (at hire, when new chemicals are introduced, annual refreshers) - What training covers (per 29 CFR 1910.1200(h)) - How training is documented - Who conducts the training - How competency is verified
OSHA requires training to cover:
- The requirements of the Hazard Communication Standard
- Any operations in the work area where hazardous chemicals are present
- The location and availability of the written program, chemical inventory, and SDSs
- How to read and interpret SDSs and labels
- Physical and health hazards of the chemicals in the work area
- Measures employees can take to protect themselves (PPE, work practices, emergency procedures)
Template language:
*All employees who may be exposed to hazardous chemicals receive hazard communication training:*
*- Initial training: Before beginning work that may involve exposure to hazardous chemicals*
*- New chemical training: When a new chemical hazard is introduced to the work area*
*- Refresher training: [Annually / per company policy]*
*Training is conducted by [Name/Title] and covers: the requirements of 29 CFR 1910.1200, the hazardous chemicals present in the employee's work area, how to read SDSs and labels, the location of the written program and SDS collection, and protective measures including PPE and emergency procedures.*
*Training is documented with a sign-in sheet that includes the date, employee name, topics covered, and trainer name. Records are maintained by [Name/Title] for [duration].*
Common mistakes: - No training records (OSHA treats "no records" as "no training") - Training that's too generic — it must cover the specific chemicals in the employee's work area - Not retraining when new chemicals are added - Relying on a single onboarding video with no documentation of who watched it
Section 7: Non-Routine Tasks
What to include: - How employees are informed about chemical hazards during non-routine tasks (one-time cleaning, equipment maintenance, confined space entry) - Who authorizes non-routine tasks involving hazardous chemicals - What additional training or precautions are required
Template language:
*Before employees perform non-routine tasks that may involve exposure to hazardous chemicals (e.g., cleaning tanks, entering confined spaces, painting, special maintenance), [Name/Title] will provide additional information about the chemical hazards involved, required protective measures, and emergency procedures specific to the task.*
Section 8: Multi-Employer Workplace / Contractor Communication
What to include: - How you share hazard information with other employers whose employees may be exposed to your chemicals - How you obtain hazard information from contractors bringing chemicals to your site - How you provide SDSs and labeling information to outside employers - Who is responsible for this communication
This section is required under 29 CFR 1910.1200(e)(2) and is one of the most overlooked elements.
Template language:
*When employees of other employers (contractors, temporary workers, service providers) may be exposed to hazardous chemicals at this worksite, [Name/Title] will:*
*- Provide the other employer with SDSs for any chemicals their employees may be exposed to*
*- Inform the other employer of any precautionary measures needed*
*- Inform the other employer of the labeling system used at this worksite*
*When outside contractors bring hazardous chemicals to this worksite, [Name/Title] will obtain SDSs for those chemicals and ensure our employees are informed of any new hazards.*
Section 9: Program Review and Updates
What to include: - How often the written program is reviewed - What triggers an update (new chemicals, process changes, organizational changes) - Who is responsible for the review
Template language:
*This written Hazard Communication Program is reviewed at least [annually] by [Name/Title] and updated as necessary to reflect changes in chemicals, processes, personnel, or regulatory requirements. Any significant changes are communicated to affected employees.*
The Template Trap: Why Most Written Programs Fail
Here's the honest truth about HazCom program templates: they work great on the day you fill them in, and they're out of date by the next week.
A template is a static document. Your workplace is not static. Chemicals come and go. Employees turn over. Manufacturers reformulate products. That template you painstakingly filled out in January is already wrong by March — but nobody updates it because that's not anyone's real job.
The most common citation OSHA issues for the written HazCom program isn't "you don't have one." It's "the one you have doesn't match your workplace." That generic template with blank fields filled in once and never touched again? That's what gets you cited.
Common Template Mistakes That Lead to Citations
- Copy-paste from another company — Inspector spots it instantly when the company name changes halfway through the document
- Generic responsibilities — "Management is responsible for..." doesn't cut it. OSHA wants names.
- Outdated chemical list — The template references chemicals you stopped using years ago and misses the ones you added last month
- Aspirational language — The program describes what you plan to do, not what you actually do
- No evidence of implementation — A beautiful document that nobody follows is just expensive wallpaper
A Better Approach: Let Your Chemical Inventory Build the Program
The written HazCom program exists to describe how you manage your chemicals. So the logical starting point is... your chemicals.
When you maintain an accurate, up-to-date chemical inventory, most of the written program writes itself:
- Your chemical list? It's your inventory.
- Your SDS collection? It maps to your inventory.
- Your labeling procedures? They follow your inventory.
- Your training content? It's driven by what's in your inventory.
The problem with templates is they separate the document from the data. You end up maintaining two things — the program and the actual chemicals — and they inevitably drift apart.
Skip the Template. Let Tellus Build It.
Tellus EHS takes a different approach. You add your chemicals to the inventory. Tellus automatically:
- Maintains your hazardous chemical list
- Manages your SDS library with current sheets for every product
- Generates your written HazCom program from your actual chemical data
- Tracks employee training completion and documentation
- Keeps everything accessible to employees from any device
No template to fill out. No annual "update the binder" ritual. No gap between what the document says and what's actually happening.
Start your 14-day free trial at tellusehs.com. Plans start at $99/month. Your written program will be more accurate than any template — because it's built from your real data, not your best guess.