HMIS and OSHA’s Hazard Communication Standard: How They Work Together
The hazardous material identification system HMIS (commonly written as HMIS) is a workplace labeling and rating method used to quickly communicate chemical hazards. Many employers use an HMIS label on secondary containers and workplace containers to support training and day-to-day safety decisions.
HMIS is widely recognized in industry, but it’s important to understand how it fits with OSHA’s Hazard Communication Standard (HazCom), 29 CFR 1910.1200. OSHA requires employers to communicate hazards through labels, Safety Data Sheets (SDSs), and employee training—but OSHA does not “approve” one proprietary label format. Instead, OSHA cares that the system you choose meets the standard’s requirements.
When implemented correctly, HMIS can be an effective hazard identification system that complements GHS-aligned SDSs and container labels, especially for in-plant containers and day-to-day handling.
What Is the Hazardous Materials Identification System (HMIS)?
The hazardous materials identification system is a color-bar label format developed to provide a quick, at-a-glance snapshot of a chemical’s hazards and recommended personal protective equipment (PPE). While exact formats can vary, an HMIS label generally includes:
- Hazard ratings (typically numerical)
- Health, Flammability, Physical Hazard categories
- A PPE indicator (letter or symbol set)
- Product identifier information (e.g., chemical name)
This type of hazardous material identification is especially useful when workers are moving between tasks and need rapid guidance—provided it’s backed by accurate SDS information and training.
HMIS vs. GHS: Not Either/Or
Under OSHA HazCom, shipped container labels must follow GHS-aligned elements (product identifier, signal word, hazard statements, pictograms, precautionary statements, and supplier info). HMIS, by contrast, is generally used for workplace/secondary labeling.
The practical approach for many organizations is:
- Use GHS-compliant shipped labels as received
- Apply workplace labels (often HMIS-style) to secondary containers, portable containers when required, or internal process containers
- Ensure the SDS library and training explain how to interpret both
HMIS can support hazard recognition at the point of use, but it should never contradict the container’s GHS label or the SDS.
OSHA Requirements That Drive HMIS Use (29 CFR 1910.1200)
OSHA’s Hazard Communication Standard is performance-based: employers must implement a program that effectively communicates hazards. Key sections that commonly relate to HMIS-style workplace labeling include:
Written Hazard Communication Program
OSHA requires a written HazCom program describing how your facility will meet labeling, SDS, and training requirements (29 CFR 1910.1200(e)). If you use HMIS for workplace labels, document:
- When HMIS labels are applied (secondary containers, process vessels, etc.)
- Who is responsible for creating/updating labels
- How ratings are determined (from SDS/GHS data)
- How contractors and new hires are trained on the system
Labeling Requirements: Shipped vs. Workplace Labels
OSHA’s labeling requirements (29 CFR 1910.1200(f)) distinguish between:
- Shipped container labels (must include GHS label elements)
- Workplace labeling (must provide, at minimum, product identifier and general hazard information consistent with HazCom)
HMIS labels are commonly used as workplace labels because they provide a structured way to convey hazard severity and PPE. However, the employer must ensure labels remain legible, in English (and other languages as needed), and consistent with the SDS.
Safety Data Sheets (SDS) Access and Accuracy
OSHA requires SDSs for hazardous chemicals and that they be readily accessible to employees during each work shift (29 CFR 1910.1200(g)). Your HMIS ratings and PPE guidance should be derived from the SDS—especially Sections 2 (Hazard(s) identification), 8 (Exposure controls/personal protection), 9 (Physical and chemical properties), 10 (Stability and reactivity), and 11 (Toxicological information).
Training: Workers Must Understand the Labeling System
Training is mandatory at initial assignment and when new hazards are introduced (29 CFR 1910.1200(h)). If you implement HMIS, training should cover:
- What each HMIS color bar/category means
- How the numerical ratings work (and what “0–4” represents at your facility)
- How PPE codes translate to actual PPE requirements
- Where to find the SDS and how to use it to make decisions
How to Read an HMIS Label (Practical Interpretation)
An HMIS label typically uses numerical ratings to communicate severity. While conventions may differ, many systems use 0 (minimal) through 4 (severe).
Common HMIS Categories
- Health: Potential for acute or chronic health effects
- Flammability: How easily the material ignites
- Physical Hazard (sometimes called Reactivity): Potential for chemical change, instability, or dangerous reactions
- PPE: A code indicating protective equipment needed (facility-specific implementation)
Because HMIS is a hazard identification system, consistency matters. If different departments assign ratings differently, the label loses value and can create risk.
Best practice: base HMIS ratings on the SDS and standardize who can approve or change ratings.
Where HMIS Helps Most in Hazardous Material Identification
HMIS can be especially effective for:
- Secondary containers (spray bottles, smaller transfer containers)
- In-plant process containers where shipped labels aren’t practical
- Maintenance and non-routine tasks where quick hazard recognition is critical
- Multi-employer worksites, when contractor training aligns with your labeling system
That said, OSHA expects workplace labels to communicate hazards clearly. If workers cannot interpret the HMIS label, or if it conflicts with the SDS, the system won’t meet HazCom’s intent.
Common HMIS/HazCom Pitfalls (and How to Avoid Them)
1. Ratings Not Tied to the SDS
If HMIS scores are assigned “from memory” or copied from outdated sources, the label may be inaccurate.
- Use current SDSs
- Update labels when SDS revisions change classifications
2. Missing Product Identifiers
OSHA expects labels to identify the chemical and allow employees to connect the label to the SDS.
- Ensure the HMIS label includes a product identifier that matches your SDS naming convention
3. Inconsistent PPE Codes
If the PPE letter/code isn’t explained, workers may default to under-protection.
- Define PPE codes in your written program
- Reinforce them in training and postings near chemical use areas
4. Poor Control of Secondary Containers
Secondary containers are a frequent compliance gap.
- Establish rules for immediate-use portable containers
- Require HMIS (or other workplace) labels when containers are stored or used beyond immediate control
Streamlining HMIS and HazCom with SwiftSDS
A major challenge with hazardous material identification is keeping SDSs, workplace labels, and training aligned—especially when chemicals move locations, inventories change, or suppliers update classifications.
SwiftSDS helps simplify this by giving you a centralized, cloud-based SDS library and tools to support a stronger HazCom program:
- Centralized SDS access so employees and supervisors can quickly find the latest SDS tied to your workplace labels
- OSHA HazCom support (29 CFR 1910.1200) by improving SDS availability and helping maintain consistency across locations
- Chemical inventory management to track chemical locations, quantities, and key dates—useful when auditing where HMIS labels should be present
- Mobile access so employees can pull SDS info on the floor, at the point of use—where HMIS labels are most relied upon
If you’re using HMIS as your workplace labeling method, SwiftSDS helps ensure that the underlying hazard information stays current and accessible, which is exactly what OSHA expects from an effective hazard communication program.
Next Steps: Make Your HMIS Labels Defensible and Worker-Friendly
HMIS can be a powerful hazardous materials identification system when it’s implemented with clear rules, consistent ratings, and training that ties directly back to the SDS. Align your HMIS approach with OSHA HazCom requirements by documenting it in your written program, maintaining current SDSs, and ensuring workers can interpret labels accurately.
Want to reduce labeling confusion and strengthen your OSHA HazCom compliance? Organize your SDS program first—then make HMIS labels consistent everywhere.
Call to action: Explore how SwiftSDS can centralize your SDS library, improve access on any device, and support a cleaner, more auditable Hazard Communication program. Get started today and bring order to your SDS and workplace labeling process with SwiftSDS. Visit SwiftSDS Features or Request a Demo.