Chemical hazards are present in virtually every manufacturing operation, from cleaning solvents and lubricants to process chemicals and raw materials. OSHA's Hazard Communication Standard (HazCom) ensures workers understand these hazards through a comprehensive system of labels, Safety Data Sheets, and training. Since adopting the Globally Harmonized System (GHS), HazCom requirements have become more standardized and effective, but also more complex. This guide covers everything manufacturers need to know about GHS-compliant labels, the 16-section SDS format, employee training requirements, and building a written HazCom program that protects workers and satisfies OSHA inspectors.
Understanding Hazard Communication
The Hazard Communication Standard, often called HazCom or the "Right to Know" rule, requires chemical manufacturers and importers to evaluate chemical hazards and communicate that information to downstream users through labels and Safety Data Sheets. Employers who use hazardous chemicals must then ensure this information reaches their workers through labels, SDS access, and training programs.
HazCom has been one of OSHA's most frequently cited standards since its inception. The violations often aren't dramatic—they're typically missing or outdated SDSs, inadequate labeling, or insufficient training. These compliance gaps create real risk: workers who don't understand chemical hazards can't protect themselves from them.
In 2012, OSHA aligned HazCom with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). This international framework standardized how chemicals are classified and how hazard information is communicated. The result is more consistent, comprehensive hazard communication that works across borders and industries.
Workers have a right to know about the hazardous chemicals they work with. That knowledge—delivered through proper labels, accessible SDSs, and effective training—is the foundation of chemical safety.
— OSHA Hazard Communication Guidance
Key Employer Responsibilities
HazCom places specific obligations on employers who use hazardous chemicals. Understanding these requirements is essential for compliance:
- Develop a written program: Create and maintain a written hazard communication program describing how your facility will meet HazCom requirements.
- Maintain chemical inventory: Keep a current list of all hazardous chemicals present in the workplace, cross-referenced with SDSs.
- Ensure proper labeling: Verify all containers of hazardous chemicals have appropriate GHS-compliant labels, including workplace containers.
- Provide SDS access: Make Safety Data Sheets readily accessible to employees during their work shifts, whether physically or electronically.
- Train employees: Provide effective training on chemical hazards, label comprehension, SDS use, and protective measures before initial exposure and when new hazards are introduced.
Multi-Employer Workplaces
When multiple employers share a workplace, the host employer must inform contractors about hazardous chemicals their employees may encounter, provide access to SDSs, and explain any protective measures needed. Contractors must do the same for chemicals they bring on-site. Document this information exchange in your written program.
GHS Classification System
The Globally Harmonized System provides standardized criteria for classifying chemical hazards. Under GHS, chemicals are evaluated against specific criteria and assigned to hazard classes and categories. This classification then determines what information appears on labels and SDSs, ensuring consistent communication worldwide.
GHS organizes hazards into three main groups: physical hazards, health hazards, and environmental hazards. Within each group are specific hazard classes, and within each class are categories indicating hazard severity. Category 1 is always the most severe, with higher numbers indicating progressively lower hazard levels.
Physical Hazards
- Flammable liquids, solids, gases, aerosols
- Explosives and self-reactive substances
- Oxidizers (liquids, solids, gases)
- Gases under pressure
- Pyrophoric and self-heating substances
- Organic peroxides
- Corrosive to metals
- Substances reactive with water
Health Hazards
- Acute toxicity (oral, dermal, inhalation)
- Skin corrosion and irritation
- Serious eye damage and irritation
- Respiratory or skin sensitization
- Germ cell mutagenicity
- Carcinogenicity
- Reproductive toxicity
- Target organ toxicity (single/repeated)
- Aspiration hazard
DANGER
Used for more severe hazard categories. Indicates potentially life-threatening or serious hazards requiring immediate attention and strict precautions.
WARNING
Used for less severe hazard categories. Indicates hazards that could cause harm but are generally less immediately dangerous than "Danger" hazards.
Classification vs. Labeling
Chemical manufacturers and importers are responsible for classification. As an employer using chemicals, you rely on their classifications but must ensure the information reaches your workers through proper labeling and training. If you believe a classification is incorrect or incomplete, contact your supplier, but do not modify labels or SDSs without authorization.
GHS Label Requirements
GHS labels use standardized elements to communicate chemical hazards at a glance. Every label on a hazardous chemical container shipped to your facility must include six required elements. Understanding these elements helps workers quickly identify hazards and know how to protect themselves.
The most recognizable GHS feature is the set of nine pictograms—red-bordered diamonds containing black symbols on white backgrounds. Each pictogram represents specific hazard types. A single chemical may require multiple pictograms if it presents multiple hazards.
Oxidizer
Flame Over Circle
Oxidizing gases, liquids, solids
Flame
Fire Hazard
Flammables, pyrophorics, self-heating
Exploding Bomb
Explosion Hazard
Explosives, self-reactives, organic peroxides
Exclamation Mark
Irritant/Narcotic
Irritants, sensitizers, narcotic effects
Health Hazard
Serious Health Effects
Carcinogens, mutagens, organ toxicity
Skull and Crossbones
Acute Toxicity
Fatal or toxic if inhaled, ingested, or absorbed
Corrosion
Corrosive
Skin corrosion, eye damage, metal corrosion
Gas Cylinder
Compressed Gas
Gases under pressure
Environment
Environmental Hazard
Aquatic toxicity (not required by OSHA)
Required GHS Label Elements
1 Product Identifier
Chemical name or code number that matches the SDS. Must be identical on label and SDS.
2 Signal Word
"Danger" or "Warning" indicating the relative severity of hazard. Only one signal word per label.
3 Pictogram(s)
Red-bordered diamond(s) with black symbol on white background. Multiple pictograms if multiple hazards.
4 Hazard Statement(s)
Standardized phrases describing the nature and severity of hazards (e.g., "Highly flammable liquid and vapor").
5 Precautionary Statements
Measures to minimize or prevent adverse effects: Prevention, Response, Storage, and Disposal instructions.
6 Supplier Information
Name, address, and telephone number of the chemical manufacturer, importer, or responsible party.
Workplace Container Labeling
When chemicals are transferred from original containers into workplace containers, labeling requirements apply. OSHA provides flexibility here—workplace labels don't need all six GHS elements, but must include at minimum the product identifier and words, pictures, symbols, or a combination that provides general hazard information.
Many employers use simplified workplace labels showing the product name, pictograms, and a reference to the SDS. Others use color-coded systems or NFPA/HMIS labels if employees are trained to understand them. Whatever system you choose, ensure workers can identify the chemical and its hazards.
Immediate Use Exception
Workplace labeling requirements don't apply to portable containers used for immediate use by the employee who performs the transfer. However, "immediate use" means within the same work shift by the same person. If a container might be used by someone else or left overnight, it needs a label. When in doubt, label it.
Safety Data Sheets (SDS)
Safety Data Sheets provide comprehensive information about hazardous chemicals, far more detail than labels can convey. Under GHS, SDSs follow a standardized 16-section format, making it easier to find specific information quickly. Chemical manufacturers and importers must provide SDSs; employers must ensure workers have access to them.
SDSs must be readily accessible during each work shift to employees when they're in their work areas. "Readily accessible" can mean physical binders in work areas, computer access to electronic databases, or other immediate methods. If electronic access is provided, ensure backup systems exist for power outages or computer failures.
The 16 Sections of a GHS Safety Data Sheet
1Identification
Product identifier, supplier info, recommended use, emergency contact
2Hazard(s) Identification
GHS classification, label elements, other hazards
3Composition/Ingredients
Chemical identity, common names, CAS numbers, concentrations
4First-Aid Measures
Symptoms, required treatment by exposure route
5Fire-Fighting Measures
Suitable extinguishing media, hazards from fire, protective equipment
6Accidental Release
Personal precautions, containment methods, cleanup procedures
7Handling and Storage
Safe handling practices, incompatibilities, storage conditions
8Exposure Controls/PPE
Exposure limits, engineering controls, PPE requirements
9Physical/Chemical Properties
Appearance, odor, pH, flash point, solubility, etc.
10Stability and Reactivity
Chemical stability, hazardous reactions, conditions to avoid
11Toxicological Information
Routes of exposure, symptoms, acute/chronic effects
12Ecological Information*
Environmental fate, ecotoxicity, bioaccumulation
13Disposal Considerations*
Waste treatment methods, disposal recommendations
14Transport Information*
DOT classification, UN number, shipping name
15Regulatory Information*
Safety, health, environmental regulations
16Other Information
Date of preparation, revision date, version, other data
*Sections 12-15 are not enforced by OSHA but must be present on the SDS
SDS Management Best Practices
| Practice | Description | Benefits |
|---|---|---|
| Centralized Database | Use electronic SDS management system with search functionality | Quick access, automatic updates, inventory tracking |
| Regular Audits | Compare chemical inventory against SDS collection quarterly | Identifies missing SDSs, removes obsolete sheets |
| Backup Systems | Maintain physical binders or offline access for emergencies | Ensures access during power/network outages |
| Request Procedures | Establish process to obtain SDSs for new chemicals before use | Prevents chemicals arriving without documentation |
| Employee Training | Train workers how to locate and use SDSs | Workers can access information when needed |
Missing SDS Protocol
If you can't locate an SDS for a chemical in your workplace, request it from your supplier immediately. Manufacturers and distributors must provide SDSs upon request. Until the SDS is obtained, restrict use of the chemical and inform workers about the missing information. Document your requests and the supplier's response.
Employee Training Requirements
Training is where hazard communication becomes real protection. Labels and SDSs only work if workers understand them. OSHA requires training before employees work with hazardous chemicals and whenever new chemical hazards are introduced. Training must be effective—it's not just about checking a compliance box.
Effective HazCom training helps workers recognize hazards, understand protective measures, and know how to respond to emergencies. It should be specific to your workplace chemicals, not generic chemical safety information. Workers need to know about the actual chemicals they encounter, not theoretical hazards they'll never face.
Required HazCom Training Topics
HazCom Standard Overview
- Requirements of the standard
- Employee rights and protections
- Location of written program
- Where chemical list is maintained
Chemical Hazards Present
- Physical hazards in work area
- Health hazards from chemicals used
- Symptoms of overexposure
- Routes of exposure (inhalation, skin, etc.)
GHS Labels
- How to read GHS labels
- Meaning of each pictogram
- Signal words and hazard statements
- Workplace labeling system
Safety Data Sheets
- How to access SDSs
- Understanding the 16-section format
- Finding specific information quickly
- When to consult an SDS
Protective Measures
- Required PPE for specific chemicals
- Engineering controls in place
- Safe work practices
- Proper storage requirements
Emergency Procedures
- Spill response procedures
- First aid for chemical exposure
- Emergency contact information
- Evacuation routes if needed
When Retraining is Required
Initial training is just the beginning. OSHA requires additional training when new chemical hazards are introduced to the workplace. This doesn't mean retraining for every new product—if a new chemical presents hazards similar to existing training, workers are already prepared. But new hazard types, new exposure scenarios, or significantly more dangerous chemicals require additional training.
- New hazard types: Introducing chemicals with hazard classes workers haven't been trained on (e.g., first carcinogen, first oxidizer).
- New protective measures: Different PPE requirements, new engineering controls, or changed work practices.
- Process changes: New operations, equipment, or procedures that change how workers interact with chemicals.
- Incident follow-up: After chemical-related incidents revealing training gaps or misunderstandings.
Make Training Practical
Effective training uses real examples from your workplace. Show workers the actual labels on chemicals they use, practice finding information in real SDSs, and discuss specific scenarios they might encounter. Generic training slides about chemicals workers never see provide compliance but not protection. The goal is workers who can actually use what they learned.
Written HazCom Program
Every employer with hazardous chemicals must maintain a written hazard communication program. This document serves as the blueprint for how your facility meets HazCom requirements. It must be available to employees, their designated representatives, OSHA inspectors, and NIOSH representatives upon request.
The written program doesn't need to be elaborate, but it must address key components. Think of it as your facility-specific plan for communicating chemical hazards. It should be a living document, updated when chemicals, processes, or procedures change.
Required Written Program Components
Chemical Inventory List
Complete list of all hazardous chemicals present in the workplace
Labeling Procedures
How incoming and workplace container labels are managed
SDS Management
How SDSs are obtained, maintained, and made accessible
Training Program
How employees will be informed and trained about hazards
Non-Routine Tasks
Procedures for hazardous non-routine tasks
Contractor Communication
How hazard info is exchanged with on-site contractors
Multi-Location Considerations
Employers with multiple locations can develop a single written program covering all sites, provided it addresses location-specific elements like chemical inventories and responsible personnel. Alternatively, each location can maintain its own program. Either approach works as long as all required elements are addressed for each workplace.
Keep It Current
Review your written program at least annually and whenever significant changes occur. New chemicals, changed processes, contractor arrangements, or organizational changes may require updates. Date each version and maintain records of revisions. An outdated written program that doesn't reflect current practices is a common citation and suggests broader program weaknesses.
OSHA Compliance Requirements
The Hazard Communication Standard (29 CFR 1910.1200) is consistently among OSHA's most frequently cited standards. Understanding the regulatory requirements helps you avoid common violations and build a defensible compliance program. The standard applies to any workplace where employees may be exposed to hazardous chemicals under normal conditions or in foreseeable emergencies.
Compliance isn't just about avoiding citations—it's about ensuring workers actually understand chemical hazards. When OSHA inspectors evaluate HazCom programs, they look for evidence that the program functions effectively, not just that paperwork exists.
OSHA Compliance Checklist
Written Program
- Written program developed and maintained
- Available to employees upon request
- Addresses all required elements
- Updated when changes occur
Chemical Inventory
- Complete list of hazardous chemicals
- Cross-referenced with SDSs
- Updated when chemicals added/removed
- Accessible to employees
Labels
- Shipped containers have GHS labels
- Labels legible and not defaced
- Workplace containers labeled
- Employees understand labeling system
Safety Data Sheets
- SDS for every hazardous chemical
- Readily accessible during shifts
- 16-section GHS format
- Backup access system available
Training
- Initial training before chemical work
- Covers all required topics
- Retraining for new hazards
- Training documented
Contractor Communication
- Inform contractors of chemical hazards
- Provide SDS access to contractors
- Contractors inform you of their chemicals
- Document information exchange
Most Common HazCom Violations
The most frequently cited HazCom violations involve training deficiencies, missing or inaccessible SDSs, unlabeled workplace containers, and inadequate written programs. These violations are often interconnected—weak written programs lead to inconsistent labeling and training. Focus on program fundamentals and the operational details will follow.
Documentation Requirements
While OSHA doesn't mandate specific training documentation formats, you must be able to demonstrate that required training occurred. Maintain records showing employee names, training dates, topics covered, and trainer identification. These records prove compliance during inspections and help track retraining needs.
Program Management Best Practices
A HazCom program is not a one-time implementation—it requires ongoing management to remain effective. Chemicals change, processes evolve, employees turn over, and regulations update. Strong program management ensures your HazCom efforts protect workers and maintain compliance over time.
The most effective programs designate clear responsibility, establish routine review processes, and integrate HazCom into broader safety management systems. They treat chemical hazard communication as an ongoing operational function, not just a compliance requirement.
1
Designate Responsibility
Assign a qualified person to oversee the HazCom program, including maintaining the chemical inventory, managing SDSs, coordinating training, and updating the written program.
2
Integrate Purchasing
Establish procedures requiring SDS receipt before new chemicals enter the workplace. Include HazCom considerations in purchasing decisions and vendor evaluations.
3
Conduct Regular Audits
Periodically walk through work areas checking labels, verifying SDS accessibility, and observing whether workers demonstrate hazard awareness.
4
Track Training Status
Maintain systems to identify who needs initial training, who requires retraining for new hazards, and when training was last completed.
Essential Program Documentation
Written Program
Current version with revision dates
Chemical Inventory
Complete list with SDS cross-reference
SDS Collection
Organized, accessible, current sheets
Training Records
Individual training documentation
Audit Reports
Program evaluation findings
Incident Reports
Chemical exposure documentation
Contractor Records
Information exchange documentation
SDS Requests
Supplier request/response tracking
Substitute Less Hazardous Chemicals
The best hazard communication is about hazards that don't exist. Regularly evaluate whether less hazardous alternatives could replace dangerous chemicals in your processes. Substitution eliminates hazards at the source, reducing the burden of labels, SDSs, training, and protective measures. Even when alternatives cost more, reduced compliance costs and lower injury risk often justify the investment.
Protecting Workers Through Communication
Effective hazard communication protects workers by ensuring they understand the chemicals they work with. GHS-compliant labels provide at-a-glance hazard information. Safety Data Sheets deliver comprehensive details for handling, emergencies, and protection. Training transforms that information into practical knowledge workers can apply daily.
Building a strong HazCom program requires attention to fundamentals: maintain a current chemical inventory, ensure every hazardous chemical has an accessible SDS, verify labels are present and legible, train workers effectively, and document your efforts. These foundational elements, consistently maintained, create a program that protects workers and satisfies regulatory requirements.
Chemical hazards are manageable when workers have the information they need. First Underwriters Insurance Brokers specializes in manufacturing risk management and can help evaluate your hazard communication program, identify compliance gaps, and develop strategies for improvement. Contact us to learn how our risk management specialists can help protect your workforce while controlling your insurance costs.