OSHA's Hazard Communication Standard (29 CFR 1910.1200), aligned with the Globally Harmonized System (GHS), requires employers to inform employees about chemical hazards in the workplace through a comprehensive program that includes a written plan, chemical inventory, safety data sheets (SDS), container labeling, and employee training. A program audit evaluates whether all elements of your hazard communication program are properly implemented and maintained. HazCom is consistently among OSHA's most frequently cited standards, making regular self-audits critical for compliance.
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Download Checklist (.docx)Regulatory Requirements
OSHA 29 CFR 1910.1200 — Hazard Communication Standard
The HazCom standard requires chemical manufacturers and importers to classify chemical hazards and communicate them through labels and safety data sheets. Employers must develop a written hazard communication program, maintain an SDS for each hazardous chemical, ensure proper labeling, and provide employee training. The standard aligns with the GHS for classification and labeling.
GHS Alignment — HazCom 2012 and 2024 Updates
OSHA's 2012 HazCom update aligned with GHS Revision 3, requiring standardized 16-section SDS format, GHS label elements (pictograms, signal words, hazard statements, precautionary statements), and uniform hazard classification criteria. The 2024 update further aligns with GHS Revisions 7 through 9, adding requirements for small container labeling and concentration range reporting.
Multi-Employer Workplaces
In multi-employer workplaces, the producing employer must provide SDS to other employers. All employers must ensure their employees have access to SDS for chemicals they may be exposed to. Contractors must be informed of chemical hazards in their work areas and have access to SDS.
Written Program
| Audit Item | Expected Finding / What to Evaluate |
|---|---|
| Written HazCom program | A written hazard communication program exists and is specific to the workplace. The program describes how labeling, SDS, and training requirements will be met. The program is available to all employees during their work shifts. |
| Chemical inventory | A complete list of all hazardous chemicals known to be present in the workplace is maintained. The inventory is current and updated when new chemicals are introduced or removed. The inventory matches the SDS collection. |
| Multi-employer provisions | If applicable, the written program addresses how chemical hazard information will be shared with contractors and other employers on-site. Methods for providing access to SDS are documented. Contractor notification procedures are in place. |
| Non-routine tasks | The program addresses how employees performing non-routine tasks are informed of chemical hazards they may encounter. Procedures exist for communicating hazards associated with chemicals in unlabeled pipes, vessels, or systems. |
Safety Data Sheets
| Audit Item | Expected Finding / What to Evaluate |
|---|---|
| SDS availability | An SDS is maintained for every hazardous chemical on the chemical inventory. SDS are readily accessible to all employees during their work shifts. Access methods (binders, electronic systems, online databases) are functioning and employees know how to access them. |
| SDS format | All SDS follow the standardized 16-section GHS format. SDS contain all required information including hazard identification, composition, first aid measures, firefighting measures, handling and storage, exposure controls, and toxicological information. |
| SDS currency | SDS are current versions provided by manufacturers. Process exists to request updated SDS from suppliers. Outdated SDS are replaced when new versions are received. SDS for chemicals no longer in use are retained per record retention policy. |
| SDS for received chemicals | A process exists to obtain SDS for all newly purchased hazardous chemicals before employees use them. Purchasing or receiving procedures include SDS verification. Missing SDS are requested from manufacturers within a reasonable timeframe. |
Labeling
| Audit Item | Expected Finding / What to Evaluate |
|---|---|
| Manufacturer labels | All incoming containers retain the manufacturer's original label. Labels include product identifier, signal word, hazard statement(s), pictogram(s), precautionary statement(s), and manufacturer contact information per GHS requirements. |
| Workplace labels | All secondary/workplace containers are labeled with at least the product identifier and words, pictures, symbols, or a combination that provides general information regarding the hazards of the chemical. Labels are legible and prominently displayed. |
| Small container labeling | Containers of 100 mL or less that are for immediate use by the employee who transferred the chemical may be exempt from labeling if the employee maintains direct control. All other small containers are labeled appropriately. |
| Piping and process labeling | Stationary process containers, piping systems, and vessels are identified using labels, placards, signs, or other means that identify the chemical and associated hazards. Employees are trained on the identification system used. |
Training
| Audit Item | Expected Finding / What to Evaluate |
|---|---|
| Initial training | All employees who may be exposed to hazardous chemicals have received initial training before starting work with or near the chemicals. Training covers the HazCom program, chemical hazards in the work area, SDS access, labeling system, and protective measures. |
| Training content | Training includes methods to detect chemical releases, physical and health hazards of chemicals in the work area, measures employees can take to protect themselves, and details of the employer's written HazCom program including labeling, SDS, and how to obtain hazard information. |
| New chemical training | Additional training is provided when new chemical hazards are introduced into the work area. Employees are informed of new hazards before working with or near new chemicals. Training covers the specific hazards of the new chemical. |
| Training documentation | Training records include employee names, dates, topics covered, and trainer identification. Records demonstrate all affected employees have completed required training. Refresher training schedule is maintained. |
Corrective Actions
Common Issues and Responses
- Missing written program: Develop a workplace-specific written HazCom program immediately. Include all required elements: chemical inventory, SDS management, labeling procedures, training program, and multi-employer communication.
- Incomplete chemical inventory: Conduct a comprehensive facility walk-through to identify all hazardous chemicals. Update the inventory to match actual chemicals present. Cross-reference inventory against SDS collection and resolve gaps.
- Missing or outdated SDS: Request current SDS from manufacturers for any missing or outdated sheets. Implement a systematic process for SDS updates during chemical purchasing. Verify SDS collection matches the complete chemical inventory.
- Labeling deficiencies: Inspect all primary and secondary containers for proper labeling. Replace missing or illegible labels. Ensure GHS-compliant labels on all incoming containers. Establish workplace labeling standards for secondary containers.
- Training gaps: Identify all employees requiring initial or refresher training. Schedule and conduct HazCom training covering all required elements. Document training and establish procedures for ongoing new-chemical training.
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Chemical Management
Digital SDS management, chemical inventory tracking, and hazard communication.
Training
HazCom training tracking with automatic reminders for new chemical introductions.
Inspections
Label compliance inspections and SDS availability verification on mobile devices.
Document Management
Centralized SDS storage with version control and access logging.
Compliance Calendar
Track SDS update cycles, training deadlines, and chemical review dates.
Task Management
Assign and track corrective actions from HazCom audits and inspections.
