components of exposure control plan

What is an exposure control plan in chemical safety?

An exposure control plan is a structured, written program that explains how your organization will identify, evaluate, and control employee exposure to hazardous chemicals. In many workplaces, the “exposure control plan” concept is discussed alongside OSHA’s Hazard Communication Standard (HCS), 29 CFR 1910.1200, which requires employers to maintain a written hazard communication program, ensure chemical labeling, provide access to Safety Data Sheets (SDSs), and train employees.

When people ask what the components of exposure control plan are, they’re typically looking for the practical elements that turn chemical safety rules into daily operating controls. Put simply, a written exposure control plan will define who does what, how hazards are communicated, which controls are used, and how the program is maintained over time.

One function of a written exposure control plan is to make exposure controls consistent and auditable—so employees can follow the same safe steps every time and the employer can prove those steps are in place.

Why a written exposure control plan matters (OSHA context)

OSHA standards don’t always use the exact phrase “exposure control plan” for general industry chemicals, but OSHA does require multiple written programs that serve the same purpose: controlling exposure through documented procedures. For chemical safety, the cornerstone is the written Hazard Communication Program under 29 CFR 1910.1200(e). Depending on your operations, other OSHA standards may also require exposure assessments and controls (for example, substance-specific standards for certain chemicals).

A strong plan helps you:

• Reduce employee exposure and prevent illness/injury
• Ensure consistent use of controls and PPE
• Demonstrate compliance during inspections
• Improve incident response when spills or overexposures occur

Core components of an exposure control plan (chemical safety)

Below are widely accepted components of exposure control plan documentation for chemical safety programs. You can tailor the depth to your workplace size and chemical risk.

Scope, purpose, and responsibilities

Start with a clear statement of:

• Which locations, departments, and job roles are covered
• The types of hazardous chemicals included (e.g., solvents, corrosives, compressed gases)
• The safety objectives (reducing exposures below applicable limits, preventing skin/eye contact, controlling flammability risks)

Define responsibilities so nothing falls through the cracks:

• Program administrator (EHS, safety manager, operations manager)
• Supervisors (implementation, enforcement)
• Employees (safe work practices, reporting)
• Purchasing/receiving (chemical approval and intake controls)

Hazard identification and chemical inventory

You can’t control exposure to chemicals you haven’t identified. A robust plan includes:

• A chemical inventory with product name, manufacturer, quantity, and location
• A process for approving new chemicals before purchase
• A method for tracking containers from receiving to point-of-use

OSHA’s HCS requires that employers maintain a list of hazardous chemicals and ensure SDS access (see 29 CFR 1910.1200(e)(1) and 1910.1200(g)).

SwiftSDS supports this step by centralizing your SDS library and linking SDSs to chemical inventory data (locations, quantities, and expiration dates), which makes it easier to keep an accurate list and provide fast access.

Safety Data Sheets (SDS) management and access

A plan should describe how SDSs are:

• Collected and kept current (latest revision)
• Organized (by product name, site, department)
• Made readily accessible during each work shift

OSHA requires SDSs to be readily accessible to employees (see 29 CFR 1910.1200(g)(8)). The plan should also specify what happens when an SDS is missing or outdated.

SwiftSDS helps by providing a secure, cloud-based SDS repository with mobile access, so workers can retrieve SDS information instantly at the point of use—without searching through binders.

Exposure assessment and risk evaluation

Your plan should explain how you determine which tasks may cause exposure and how you evaluate risk. This often includes:

• Reviewing SDS hazard information (Sections 2, 8, 9, 10, 11)
• Identifying exposure routes (inhalation, skin, ingestion, injection)
• Determining frequency/duration of tasks (e.g., daily solvent wipe-down)
• Air monitoring or industrial hygiene sampling when needed
• Comparing results to applicable exposure limits (e.g., OSHA PELs where applicable)

Document triggers for reassessment, such as:

• New chemical introduction
• Process changes
• Complaints/health symptoms
• Incident or spill

Control measures (hierarchy of controls)

A critical part of the components of exposure control plan is documenting what controls will be used and when. Use the hierarchy of controls:

1. Elimination/Substitution: Remove the chemical or use a safer alternative.
2. Engineering controls: Local exhaust ventilation, closed transfer systems, dilution ventilation, splash guards.
3. Administrative controls: Task rotation, reduced quantities, restricted access, scheduling high-exposure tasks off-shift.
4. Work practices: No eating/drinking in chemical areas, proper decanting, hygiene and handwashing rules.
5. PPE: Gloves, goggles/face shields, aprons, respirators (when required).

Your plan should specify who approves controls, how they’re selected, and how effectiveness is verified.

Personal protective equipment (PPE) and respiratory protection integration

PPE should never be vague (“wear gloves”). The plan should document:

• PPE selection criteria tied to chemical hazards (compatibility, breakthrough times)
• Required PPE by task and area
• Storage, inspection, replacement, and disposal requirements

If respirators are needed, ensure alignment with OSHA’s Respiratory Protection Standard, 29 CFR 1910.134, including medical evaluations, fit testing, and training.

Labeling and secondary container management (GHS)

The plan must describe labeling rules for:

• Primary containers received from suppliers (must not be defaced)
• Secondary containers (spray bottles, beakers, small jars)
• Portable containers intended for immediate use

OSHA’s HCS incorporates GHS-aligned labeling elements (signal word, pictograms, hazard statements, precautionary statements) and requires workplace labeling systems to communicate hazards effectively (see 29 CFR 1910.1200(f)).

SwiftSDS supports GHS classification and labeling workflows, helping teams keep hazard information consistent across sites and containers.

Training and communication

Training is where written plans become real behavior. Under 29 CFR 1910.1200(h), employees must be trained on hazardous chemicals in their work area at the time of initial assignment and whenever new hazards are introduced.

Your exposure control plan should include:

• Training topics (SDS navigation, label elements, exposure routes, protective measures)
• How training is delivered (classroom, toolbox talk, digital)
• Documentation and refresher intervals
• Contractor/temporary worker communication

Housekeeping, storage, and handling procedures

Chemical safety exposures often come from poor storage and routine handling. Include procedures for:

• Segregating incompatibles (acids/bases, oxidizers/organics)
• Flammable storage requirements and control of ignition sources
• Waste accumulation, labeling, and disposal coordination
• Cleaning methods that minimize airborne exposure (avoid dry sweeping powders)

Tie these procedures back to SDS handling and storage recommendations.

Spill response, emergency procedures, and medical response

Your plan should clearly define what to do when controls fail:

• Spill classification (minor vs. major) and response steps
• Required spill kits and where they’re located
• Evacuation, ventilation shutdown, and isolation procedures
• First aid and decontamination (eye wash/shower locations)
• Incident reporting and post-incident review

Align emergency elements with other workplace programs (e.g., emergency action planning) as applicable.

Program review, audits, and recordkeeping

A written plan is only effective if it stays current. Include:

• Review frequency (at least annually or upon changes)
• Inspection/audit checklists (labels, SDS access, storage, PPE)
• Corrective action tracking
• Recordkeeping for training, monitoring, and incidents

This is another place where centralization helps: SwiftSDS enables consistent document control and rapid retrieval of SDS and chemical inventory data during audits.

Common pitfalls to avoid

Even well-intended programs fail when the plan isn’t operational. Watch for:

• SDSs stored in a binder that employees can’t access during the shift
• Inventory lists that don’t match what’s on the floor
• Secondary containers left unlabeled
• PPE “recommendations” without compatibility verification
• No defined trigger for reassessing exposure when processes change

How SwiftSDS strengthens exposure control planning

An exposure control plan depends on accurate chemical data and fast access to hazard information. SwiftSDS supports chemical safety by:

• Maintaining a centralized SDS library accessible from any device
• Supporting OSHA HCS (29 CFR 1910.1200) alignment with organized hazard communication documentation
• Enabling chemical inventory management (locations, quantities, expiration dates)
• Improving response readiness by making SDS emergency information available immediately

For organizations managing multiple sites or frequent chemical changes, SwiftSDS reduces the administrative burden while improving day-to-day compliance.

Call to action

If you’re updating your hazard communication program or building out the components of exposure control plan for chemical safety, start by tightening SDS access, inventory accuracy, and documented control procedures. Explore how SwiftSDS can simplify compliance and make SDS information instantly available to your teams—visit SwiftSDS to request a demo or learn more.