Hazard Communication
HazCom / GHS Compliance

Why HazCom Matters

OSHA's Hazard Communication Standard 29 CFR 1910.1200 is consistently among the top five most-cited violations every year. The standard — often called the "right-to-know" rule — requires employers to inform workers about the hazardous chemicals they may be exposed to in the workplace. In 2012, OSHA aligned HazCom with the Globally Harmonized System (GHS) of Classification and Labelling of Chemicals, creating a uniform framework for chemical hazard communication worldwide.

The standard applies to any employer with workers who may be exposed to hazardous chemicals under normal conditions of use or in a foreseeable emergency. This includes manufacturing, construction, healthcare, laboratories, maintenance, and virtually every industry where chemicals are present — from cleaning solvents and paints to welding gases and pesticides.

Written Hazard Communication Program

Every covered employer must develop, implement, and maintain a written HazCom program 1910.1200(e). This document serves as the blueprint for your facility's chemical safety management. It must include:

• Chemical inventory — a complete list of all known hazardous chemicals present in the workplace.
• Methods for labeling — how containers (both manufacturer and workplace) will be labeled.
• SDS management — how Safety Data Sheets will be obtained, maintained, and made accessible to employees during each work shift.
• Employee training — the plan for initial and refresher training whenever new chemical hazards are introduced.
• Non-routine tasks — procedures for informing employees about hazards during non-routine tasks such as cleaning reactor vessels or spill response.
• Multi-employer workplaces — how the employer will inform contractors and other employers about chemical hazards at the site.

The written program must be available to employees, their designated representatives, and OSHA inspectors upon request.

GHS Classification and Labels

The GHS alignment brought standardized hazard classification criteria, label elements, and SDS format to the United States. Under GHS, every hazardous chemical is classified by hazard class (e.g., flammable liquid, acute toxicity, carcinogenicity) and hazard category (severity ranking within that class, with Category 1 typically being the most severe).

GHS Label Elements

Manufacturer labels on shipped containers must include six GHS-required elements 1910.1200(f)(1):

The Nine GHS Pictograms

GHS uses nine standardized pictograms: Flame, Flame Over Circle (oxidizers), Exploding Bomb, Corrosion, Gas Cylinder, Skull and Crossbones (acute toxicity), Exclamation Mark (irritant/narcotic), Health Hazard (carcinogen/sensitizer/organ toxicity), and Environment (aquatic toxicity). In the U.S., the Environment pictogram is not mandatory under OSHA but may appear on labels from international suppliers.

Workplace Container Labeling

When chemicals are transferred to secondary containers for workplace use, those containers must also be labeled — but employers have more flexibility 1910.1200(f)(6). Workplace labels must include at minimum the product identifier and words, pictures, symbols, or a combination that provide general information about the hazards of the chemical. Many employers use the NFPA 704 diamond, HMIS labels, or simplified GHS labels for workplace containers.

Safety Data Sheets (SDS)

The GHS-aligned SDS replaced the older Material Safety Data Sheet (MSDS) format with a standardized 16-section format 1910.1200(g). Every SDS must follow this exact sequence:

*Sections 12–15 are enforced by agencies other than OSHA (EPA, DOT) but must still be present on the SDS.

Employers must ensure that SDSs are readily accessible to employees during each work shift. Electronic access (binder stations, SDS management software, or mobile apps) is acceptable provided employees can access them without delay and are trained on how to retrieve them.

Training Requirements

Employers must provide effective training at the time of initial assignment and whenever a new chemical hazard is introduced into the work area 1910.1200(h). Training must cover:

• The requirements of the HazCom standard itself.
• Operations in the work area where hazardous chemicals are present.
• The location and availability of the written HazCom program, chemical inventory, and SDSs.
• How to read and interpret GHS labels and SDSs.
• Physical and health hazards of chemicals in the work area.
• Protective measures — engineering controls, work practices, and PPE.
• Emergency procedures, including spill response and first aid.

Most Common HazCom Citations

HazCom violations accounted for over 2,400 citations in federal OSHA's most recent fiscal year. The most frequently cited provisions include:

• No written program or the written program does not address all required elements.
• Missing or incomplete SDSs — every hazardous chemical must have an accessible SDS.
• Unlabeled secondary containers — transferred chemicals without proper workplace labels.
• Inadequate training — training that does not cover GHS label elements or SDS interpretation.
• Outdated information — failure to update the chemical inventory or obtain new SDSs when products change.

References