Chemical Safety

although osha created no symbols

chemical safetyalthough osha created no symbols, in which workplaces are written hazard communication programs not required, although osha created no symbols or specific color designations

Although OSHA Created No Symbols: What That Means for Chemical Safety

A common misconception in chemical safety is that OSHA “made” the hazard symbols used on labels and Safety Data Sheets. In reality, although OSHA created no symbols, OSHA regulates the system employers must use to communicate chemical hazards—primarily through the Hazard Communication Standard (HazCom), 29 CFR 1910.1200. HazCom requires that chemical hazards be identified and communicated, but it does not invent the pictograms themselves.

Today, most U.S. workplaces follow the Globally Harmonized System (GHS) framework for classification and labeling. OSHA adopted key elements of GHS into HazCom, standardizing how hazards are conveyed without “creating” new iconography from scratch. Understanding this distinction matters because it helps employers focus on what OSHA actually enforces: labels, Safety Data Sheets, training, and a hazard communication program.

OSHA’s Role: Standards and Requirements, Not Custom Symbols

OSHA’s HazCom standard is performance-based in its intent (ensuring employees understand chemical hazards) and prescriptive in its core components (what must be on labels and SDSs, what training must include, and when a written program is required).

“Although OSHA Created No Symbols or Specific Color Designations”

It’s accurate to say although OSHA created no symbols or specific color designations, OSHA still mandates that hazard communication be effective and consistent with HazCom requirements.

Under 29 CFR 1910.1200(f), shipped container labels must include:

  • Product identifier
  • Signal word
  • Hazard statement(s)
  • Precautionary statement(s)
  • Pictogram(s)
  • Supplier identification

Those pictograms align with GHS conventions (e.g., flame, skull and crossbones). OSHA enforces whether labels contain the required elements and whether they are legible and in English (other languages can be added).

Key takeaway: OSHA didn’t design the pictograms, but OSHA requires that employers use compliant labeling elements and maintain accessible, accurate SDSs.

The Written Hazard Communication Program: When It’s Required (and When It’s Not)

A major compliance pillar is the written HazCom program required by 29 CFR 1910.1200(e) for employers with hazardous chemicals in the workplace. This is where many questions arise, including: in which workplaces are written hazard communication programs not required?

In Which Workplaces Are Written Hazard Communication Programs Not Required?

In general, a written HazCom program is required for workplaces where employees may be exposed to hazardous chemicals under normal conditions of use or in foreseeable emergencies. However, HazCom contains scope limitations and exemptions in 29 CFR 1910.1200(b).

While employers should verify applicability carefully, written hazard communication programs may not be required in workplaces where HazCom does not apply—for example:

  • Workplaces with no hazardous chemicals as defined by the standard
  • Certain laboratory operations covered instead by OSHA’s Laboratory Standard (29 CFR 1910.1450) where it applies (though hazard communication still matters, and labels/SDS access may still be expected)
  • Certain consumer products when used in the workplace in the same manner and frequency as typical consumer use (per HazCom consumer product exemption conditions)

In Which Workplaces Are Written Hazard Communication Programs… Required?

If you’re asking in which workplaces are written hazard communication programs required, the practical answer is: most general industry workplaces that use, store, handle, or generate hazardous chemicals—manufacturing, warehousing, automotive, printing, construction support shops, food processing with sanitation chemicals, healthcare environmental services, and more.

A compliant written program typically addresses:

  • How you will maintain and provide access to SDSs
  • How labeling will be managed (including workplace/secondary containers)
  • How employee training will be conducted
  • How you will inform employees of non-routine tasks and hazards
  • How contractors and other employers on-site will be informed

Training: What OSHA Actually Expects

Training is where hazard communication succeeds or fails. HazCom requires that training occur at the time of initial assignment and whenever a new hazard is introduced, per 29 CFR 1910.1200(h).

Employees Exposed to Hazardous Chemicals Must Be Trained Except…

Many people search for the phrase employees exposed to hazardous chemicals must be trained except because they assume there’s a broad “training exemption.” In practice, OSHA expects training whenever employees are exposed—or could reasonably be exposed—to hazardous chemicals in their work area.

There are limited situations where training obligations may be reduced or not triggered under HazCom, such as:

  • Employees with no exposure to hazardous chemicals in their work area
  • HazCom non-applicability situations under 1910.1200(b) (where the standard does not apply)

Even then, employers should be cautious: exposure can be created by maintenance tasks, spills, or chemical transfers that aren’t part of routine work. OSHA commonly cites employers when training does not match actual work conditions.

At a minimum, HazCom training should cover:

  • How to read and understand SDSs (16-section format)
  • How to interpret label elements (signal words, hazard statements, pictograms)
  • Measures employees can take to protect themselves (PPE, ventilation, safe handling)
  • Emergency procedures and spill response expectations

Common Compliance Gaps (and How to Fix Them)

Even when employers understand that although OSHA created no symbols, they still struggle with day-to-day SDS and label control. Common issues include:

  • SDS binders that are outdated or missing sheets
  • Multiple facilities with inconsistent SDS versions
  • Employees unable to access SDSs promptly during off-hours or in the field
  • Secondary containers that are not labeled consistently
  • Training content that doesn’t match the actual chemicals onsite

How SwiftSDS Helps Simplify Hazard Communication

SwiftSDS supports chemical safety programs by centralizing the most difficult operational pieces of HazCom compliance:

  • Centralized SDS library so employees and supervisors can locate current SDSs quickly
  • Mobile access for field teams, night shifts, and remote areas of a facility
  • Chemical inventory management to track what’s onsite, where it’s stored, and what has expired
  • Support for GHS-aligned hazard information, improving label and SDS consistency
  • A practical foundation for maintaining a written HazCom program under 29 CFR 1910.1200(e)

By pairing a strong written program with reliable SDS access and inventory controls, employers can reduce confusion about pictograms, improve training relevance, and be better prepared for inspections.

Practical Steps to Strengthen Chemical Safety Today

Use this checklist to tighten your hazard communication program:

  1. Confirm HazCom applicability under 29 CFR 1910.1200(b) and document any exemptions.
  2. Maintain a written HazCom program per 1910.1200(e) and keep it site-specific.
  3. Audit your SDS collection for completeness and currency; verify employee access.
  4. Verify shipped container labels and implement a workplace labeling process for secondary containers.
  5. Train employees per 1910.1200(h), and update training when new hazards are introduced.
  6. Maintain an accurate chemical inventory so training and SDS access match reality.

If your team struggles to find SDSs quickly or keep inventories aligned across locations, a dedicated SDS management platform can be the difference between “paper compliance” and real-world readiness.

Conclusion: OSHA Didn’t Create the Symbols—But OSHA Enforces the System

Although GHS pictograms are widely recognized, it remains true that although OSHA created no symbols or specific color designations, OSHA enforces the hazard communication framework that ensures employees understand chemical risks. The focus should be on HazCom fundamentals: a written program when required, accessible SDSs, compliant labeling, and effective training.

Call to action: If you want to reduce SDS chaos, improve mobile access for workers, and strengthen HazCom readiness under 29 CFR 1910.1200, explore how SwiftSDS can streamline your program. Visit SwiftSDS SDS Management to see how a centralized library and chemical inventory tools support safer, simpler compliance.