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hazard communication program

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Hazard Communication Program: The Foundation of OSHA’s Hazard Communication Standard

A hazard communication program (often called a HazCom program) is the written, workplace-specific system an employer uses to ensure employees understand chemical hazards and can protect themselves. Under OSHA’s Hazard Communication Standard (HCS), 29 CFR 1910.1200, most workplaces that use, store, or handle hazardous chemicals must develop and implement an effective program—including how labels, Safety Data Sheets (SDSs), and employee information/training will be managed.

A strong program isn’t just “paper compliance.” It’s a practical tool that reduces injuries, supports emergency response, and improves day-to-day chemical handling. Modern SDS management platforms like SwiftSDS make it easier to keep SDS libraries current, provide mobile access to workers, and document key compliance steps.

What OSHA Requires Under the Hazard Communication Standard

OSHA’s HCS (29 CFR 1910.1200) requires employers to communicate chemical hazards through a coordinated approach. While the regulation includes many details, most compliance efforts map to a few core components.

HCS employer requirements (core elements)

HCS employer requirements generally include:

  • Written hazard communication program describing how the employer will meet HCS elements (29 CFR 1910.1200(e))
  • Chemical inventory (often called a hazardous chemical list) for known hazardous chemicals in the workplace (29 CFR 1910.1200(e)(1)(i))
  • Container labeling and other forms of warning (29 CFR 1910.1200(f))
  • Safety Data Sheets maintained and readily accessible to employees (29 CFR 1910.1200(g))
  • Employee information and hazard communication training at initial assignment and when new hazards are introduced (29 CFR 1910.1200(h))

These requirements apply broadly across general industry. Employers must tailor the program to the chemicals present, where they are used, and who may be exposed.

The Primary Source for Detailed Chemical Hazard Information

In HazCom, one phrase comes up frequently in audits and training:

The primary source for detailed chemical hazard information is the Safety Data Sheet (SDS).

Under 29 CFR 1910.1200(g), employers must ensure SDSs are readily accessible to employees in their work areas during each work shift. This is critical because SDSs contain standardized, detailed information such as:

  • Hazard classification and signal words (Section 2)
  • Composition/ingredients (Section 3)
  • First-aid measures (Section 4)
  • Fire-fighting measures (Section 5)
  • Accidental release measures (Section 6)
  • Handling and storage precautions (Section 7)
  • Exposure controls/PPE (Section 8)

SwiftSDS supports this requirement by centralizing SDSs in a secure cloud library and enabling mobile access so workers can find the right SDS quickly—without chasing paper binders or outdated files.

Building a Written Hazard Communication Program (and Why It Matters)

A written program (29 CFR 1910.1200(e)) is the backbone of HazCom. OSHA expects it to describe, in plain terms, how your workplace will manage chemical hazards. A program should not be generic; it should reflect your specific operations, departments, and chemical use patterns.

What to include in a HazCom program template

A practical hazcom program template typically includes:

  1. Workplace scope and responsible personnel
    • Who maintains the program
    • Who updates SDSs and the chemical inventory
    • Who ensures labeling and training are completed
  2. Hazardous chemical inventory process
    • How chemicals are approved, received, and added to inventory
    • How locations and quantities are tracked
    • How discontinued products are removed
  3. SDS management procedures
    • How SDSs are obtained (e.g., from suppliers/manufacturers)
    • How SDSs are stored and accessed
    • How SDSs are reviewed for completeness and updated
  4. Labeling system
    • How shipped container labels are maintained
    • How workplace/secondary container labels are created and verified
    • How alternative labeling (if used) meets requirements (29 CFR 1910.1200(f)(7))
  5. Hazard communication training program
    • Initial and refresher triggers
    • How training is documented
    • How temporary employees/contractors are addressed
  6. Non-routine tasks and unlabeled pipes
    • Procedures for tasks that may expose employees to hazards outside normal operations
  7. Multi-employer workplaces
    • How chemical hazard information is shared with contractors and other employers onsite (29 CFR 1910.1200(e)(2))

If you already have a written program but struggle with day-to-day execution, SwiftSDS can help operationalize it by tying your SDS library to chemical inventory management (locations, quantities, expiration dates) and making updates easier to control.

Hazard Communication Training: What Employees Must Learn

Under 29 CFR 1910.1200(h), employers must provide hazard communication training and information so employees understand chemical hazards in their work area.

Training topics required by OSHA

Your training must cover (at a minimum):

  • The requirements of the HCS and the employer’s HazCom program
  • Operations where hazardous chemicals are present
  • How employees can detect the presence or release of a hazardous chemical
  • Physical and health hazards of chemicals in the work area
  • Protective measures (engineering controls, safe work practices, emergency procedures, and PPE)
  • Details of the labeling system and how to read SDSs

Practical training tips for compliance

  • Train employees to locate and use SDSs quickly—especially Sections 2, 4, 6, 7, and 8.
  • Include real workplace examples: the actual products and labels employees see.
  • Reinforce that SDS access must be immediate during the shift, including when supervisors are not present.
  • Document training dates, topics, and attendee names for audit readiness.

With SwiftSDS mobile access, training can be reinforced on the floor: employees can pull up an SDS in real time during toolbox talks, onboarding, or incident reviews.

Chemical Inventory and Labeling: Common HazCom Gaps

Even with a written program, employers often struggle with execution. Two of the most common failure points are the chemical list and labeling.

Maintaining an accurate hazardous chemical list

OSHA expects the workplace chemical list to reflect what is actually present. Gaps happen when:

  • New chemicals are brought in without being added to inventory
  • Old products remain onsite past expiration or past use
  • Multiple departments store chemicals without centralized tracking

SwiftSDS addresses this by combining SDS storage with chemical inventory management, helping teams track chemical locations, quantities, and expiration dates—so the written program matches reality.

Secondary container labeling

Many incidents involve chemicals transferred into spray bottles, small containers, or process vessels. Under 29 CFR 1910.1200(f), employers must ensure workplace containers are labeled unless a specific exemption applies (e.g., immediate use by the employee who transfers it).

A written program should define:

  • When secondary labeling is required
  • What information must be on the label
  • Who is authorized to create labels and how they are verified

Keeping Your HazCom Program Audit-Ready

OSHA compliance is easier when HazCom is treated as an ongoing system rather than a one-time document.

A simple maintenance checklist

  • Review and update your written program at least annually or after major process changes
  • Reconcile your chemical inventory with purchasing and storage areas
  • Verify SDS availability for every chemical on the list
  • Spot-check labels in work areas, including secondary containers
  • Trigger hazard communication training when new hazards or chemicals are introduced

A centralized tool like SwiftSDS supports these routines by keeping SDSs organized in one place, improving access across shifts, and reducing the risk of outdated or missing documents.

Take the Next Step: Make HazCom Easier with SwiftSDS

A compliant hazard communication program is essential under OSHA’s HCS (29 CFR 1910.1200), but the real goal is safer work—clear labels, accessible SDSs, accurate inventories, and effective training.

If you’re managing SDS binders, chasing suppliers for updated sheets, or struggling to keep inventory aligned with what’s on the floor, SwiftSDS can help.

Explore how SwiftSDS streamlines SDS access, supports GHS-aligned hazard communication, and improves day-to-day compliance. Visit SwiftSDS SDS Management to schedule a demo or learn more.