HAZARD COMMUNICATION

Small Entity Compliance 

Guide for Employers That 

Use Hazardous Chemicals

OSHA 3695-03 2014
Occupational Safety and Health Act of 1970

“To assure safe and healthful working conditions for 

working men and women; by authorizing enforcement 

of the standards developed under the Act; by assisting 

and encouraging the States in their efforts to assure 

safe and healthful working conditions; by providing for 

research, information, education, and training in the field 

of occupational safety and health.”

This guidance document is not a standard or regulation, and it creates no new legal obligations. It contains 

recommendations as well as descriptions of mandatory safety and health standards. The recommendations 

are advisory in nature, informational in content, and are intended to assist employers in providing a safe 

and healthful workplace. The Occupational Safety and Health Act requires employers to comply with 

safety and health standards and regulations promulgated by OSHA or by a state with an OSHA-approved 

state plan. In addition, the Act’s General Duty Clause, Section 5(a)(1), requires employers to provide their 

employees with a workplace free from recognized hazards likely to cause death or serious physical harm.

Cover photo: Elizabeth Routh, Corpus Christi Area Office

Material contained in this publication is in the public 

domain and may be reproduced, fully or partially, without 

permission. Source credit is requested but not required.

This information will be made available to sensoryimpaired individuals upon request. 

Voice phone: (202) 693-1999; 

teletypewriter (TTY) number: 1-877-889-5627. 

This publication provides a general overview of a particular 

standards-related topic. This publication does not alter or 

determine compliance responsibilities which are set forth 

in OSHA standards, and the Occupational Safety and Health 

Act. Moreover, because interpretations and enforcement 

policy may change over time, for additional guidance on 

OSHA compliance requirements, the reader should consult 

current administrative interpretations and decisions by the 

Occupational Safety and Health Review Commission and 

the courts.
HAZARD COMMUNICATION

Small Entity Compliance 

Guide for Employers That

Use Hazardous Chemicals

Occupational Safety and Health Administration

U.S. Department of Labor

OSHA 3695-03 2014

TABLE OF CONTENTS

I. Introduction....................................................................................................................................................... 1

II. Steps to an Effective Hazard Communication Program .............................................................................. 7

1. Learn the Standard/Identify Responsible Staff ....................................................................................... 9

2. Prepare and Implement a Written Hazard Communication Program..................................................11

3. Ensure Containers are Labeled.................................................................................................................14

4. Maintain Safety Data Sheets ................................................................................................................... 20

5. Inform and Train Employees.................................................................................................................... 25

6. Evaluate and Reassess Your Program .................................................................................................... 28

III. Conclusion....................................................................................................................................................... 29

Appendix A: Sample Written Hazard Communication Program .................................................................... 30

Appendix B: Quick Guide to Hazard Communication Training ....................................................................... 33

Workers’ Rights..................................................................................................................................................... 36

OSHA Assistance, Services and Programs ....................................................................................................... 36

NIOSH Health Hazard Evaluation Program........................................................................................................ 38

OSHA Regional Offices ........................................................................................................................................ 39

How to Contact OSHA.......................................................................................................................................... 40
vi Occupational Safety and Health Administration
Hazard Communication: Small Entity Compliance Guide for Employers That Use Hazardous Chemicals 1

I. INTRODUCTION

Chemicals have become an important element 

of almost every aspect of modern life. All 

of these chemicals—from cleaning fluids to 

pharmaceuticals, pesticides, and paints—are 

produced in workplaces, and may be used in 

workplaces downstream. While these chemicals 

have utility and benefits in their applications, they 

also have the potential to cause adverse effects. 

These adverse effects include both health hazards 

(such as carcinogenicity and sensitization), and 

physical hazards (for example, flammability and 

reactivity properties). In order to protect workers 

from these effects—and to reduce the occurrence 

of chemical source illnesses and injuries—

employers need information about the hazards of 

the chemicals they use, as well as recommended 

protective measures. Workers have both a right 

and a need to know this information too, especially 

so that they can take steps to protect themselves 

when necessary.

No one knows exactly how many chemicals may be 

present in American workplaces. The total number 

of chemical substances that have been developed 

and registered in the Chemical Abstracts Service 

Registry reached 60 million in 2011—the last 10 

million of those were added in less than two years. 

Many of them involve innovations such as the 

application of nanotechnology.

While not all of these chemicals are produced 

commercially today, this vast number indicates the 

scope of the potential problems in workplaces with 

regard to the safe use of chemicals. In addition, 

most chemical substances are formulated into 

mixtures for use in the workplace. Therefore, the 

number of unique chemical mixtures is far greater 

than the number of substances, and most workers 

are exposed to mixtures.

According to the Bureau of Labor Statistics 

(BLS), acute illnesses and injuries due to chemical 

exposures in the workplace have decreased 

42% since the Hazard Communication Standard 

was first promulgated.

The scope of workplaces in which chemical 

exposures occur is also very broad. While 

most people can readily associate working in a 

chemical manufacturing plant as being a job that 

involves chemical exposures, there are many 

other types of facilities where such usage is also 

commonplace. For example, construction workers 

may be exposed to paints, lacquers, thinners, 

asphalt fumes, or crystalline silica. Hair stylists are 

exposed to chemical dyes and other hair products 

that contain hazardous chemicals. All of these 

types of exposures are of concern in terms of 

protecting workers, and ensuring that chemicals 

are used safely.

Audience for this Guide

This guide is intended to help small employers 

comply with the Occupational Safety and Health 

Administration’s (OSHA) Hazard Communication 

Standard (HCS). The guide is advisory in nature 

and informational in content. It is not itself a 

standard or regulation, and it creates no new 

legal obligations. The employer must refer to the 

appropriate standard to ensure it is in compliance. 

In 25 states and two territories, OSHA standards 

are enforced by the state agency responsible 

for the OSHA-approved state plan. These states 

are: Alaska, Arizona, California, Hawaii, Indiana, 

Iowa, Kentucky, Maryland, Michigan, Minnesota, 

Nevada, New Mexico, North Carolina, Oregon, 

Puerto Rico, South Carolina, Tennessee, Utah, 

Vermont, Virginia, Washington, and Wyoming. 

Connecticut, Illinois, New Jersey, New York, and 

the Virgin Islands operate OSHA-approved State 

Plans that apply only to state and local government 

employees. State plans must adopt and enforce 

standards that are either identical to or at least as 

effective as the Federal OSHA standards.

OSHA’s Hazard Communication Standard

OSHA’s HCS, 29 CFR 1910.1200, addresses 

the informational needs of employers and 

workers with regard to chemicals. The HCS 

was first promulgated in 1983, and covered the 

manufacturing sector. It was later expanded to 

cover all industries where workers are potentially 

exposed to hazardous chemicals. 
2 Occupational Safety and Health Administration

The revised Hazard Communication Standard is 

expected to build on the success of the original 

Hazard Communication Standard and prevent an 

estimated additional 585 injuries and illnesses and 

43 fatalities annually. It will reduce trade barriers and 

result in estimated annualized benefits in productivity 

improvements for American businesses that regularly 

handle, store and use hazardous chemicals, as well as 

cost savings for American businesses when revising 

safety data sheets and labels for chemicals covered 

under the standard.

In 2012, the HCS was modified to align its provisions 

with the United Nations’ Globally Harmonized 

System of Classification and Labelling of Chemicals 

(GHS). Many benefits will result from revising the 

HCS to be consistent with the GHS. In particular, 

the GHS helps to ensure that imported chemicals 

will be accompanied by consistent hazard and 

precautionary information to protect workers 

exposed in the U.S. In addition, the revised HCS can 

facilitate trade in chemicals since it reduces potential 

barriers posed by differing global requirements for 

classification and labeling of chemicals.

“Classification” means to identify the relevant data 

regarding the hazards of a chemical; review those 

data to ascertain the hazards associated with the 

chemical; and decide whether the chemical will be 

classified as hazardous according to the definition 

of hazardous chemical in this section. In addition, 

classification for health and physical hazards includes 

the determination of the degree of hazard, where 

appropriate, by comparing the data with the criteria 

for health and physical hazards.

“Label” means an appropriate group of written, 

printed or graphic information elements concerning 

a hazardous chemical that is affixed to, printed on, or 

attached to the immediate container of a hazardous 

chemical, or to the outside packaging.

“Safety data sheet (SDS)” means written or 

printed material concerning a hazardous chemical 

that is prepared in accordance with paragraph (g) 

of this section.

The HCS is a unique OSHA standard in a number 

of respects. It incorporates what is referred to as 

a downstream flow of information from chemical 

manufacturers, importers, and distributors, to 

employers using the products: 

■ The standard requires chemical manufacturers 

and importers to classify the hazards of the 

chemicals they produce or import, and to 

prepare appropriate labels and safety data 

sheets (SDSs) to convey the hazards, as well as 

recommended protective measures. 

■ Chemical manufacturers, importers, and 

distributors must ensure that the containers 

of these hazardous chemicals are labeled 

when shipped, and that SDSs are provided 

downstream with the first shipment and when 

the SDSs are updated.

Thus, those who know the most about the 

chemicals—the companies that produce, import, 

or distribute them—have the responsibility to 

assess available information, and convey what 

is needed to downstream employers where the 

hazardous chemicals are used. The scope of 

coverage with regard to employers is addressed in 

paragraph (b)(2) of the standard:

(b)(2) This section applies to any chemical which 

is known to be present in the workplace in such 

a manner that employees may be exposed under 

normal conditions of use or in a foreseeable 

emergency.

There are a number of definitions that impact 

the interpretation of this definition of coverage 

(see box to the left), but most workplaces will be 

subject to the rule. 

As an employer who is a chemical user, you are 

required to receive labels and SDSs from your 

suppliers. Employers have responsibilities under 

the HCS to establish hazard communication 

programs, and provide workers with access to 

labels and SDSs, in addition to informing and 

training these workers. The responsibilities 

for hazard communication are illustrated in 

Figure 1.
Hazard Communication: Small Entity Compliance Guide for Employers That Use Hazardous Chemicals 3

“Employee” means a worker who may be exposed 

to hazardous chemicals under normal operating 

conditions or in foreseeable emergencies. Workers 

such as office workers or bank tellers who encounter 

hazardous chemicals only in non-routine, isolated 

instances are not covered.

“Exposure or exposed” means that an employee 

is subjected, in the course of employment, to a 

chemical that is a physical or health hazard, and 

includes potential (e.g., accidental or possible) 

exposure. “Subjected” in terms of health hazards 

includes any route of entry (e.g., inhalation, 

ingestion, skin contact or absorption.)

“Produce” means to manufacture, process, formulate, 

blend, extract, generate, emit, or repackage.

“Use” means to package, handle, react, emit, extract, 

generate as a by-product, or transfer.

This guide addresses employer responsibilities 

under the HCS. Many of the provisions of the 

standard apply only to chemical manufacturers, 

importers, or distributors. This guide will focus 

on assisting employers that only use but do not 

produce chemicals, in order to identify the parts of 

the rule that apply to their facilities, and help them 

to develop and implement an effective hazard 

communication program. 

The 2012 revisions to the HCS, also referred to as 

“HazCom 2012” in this document, primarily address 

how chemical manufacturers and importers classify 

chemical hazards and prepare required labels 

and SDSs. If you are not a chemical manufacturer 

or importer, and you already have a hazard 

communication program that complies with the 

original HCS, you will have limited changes to make 

related to compliance with the revised standard. 

Figure 1: How Hazard Communication Works

• Chemical 

Manufacturers and 

Importers classify 

the hazards of 

chemicals they 

produce or import, 

and prepare labels 

and safety data 

sheets based on the 

classifications

Chemicals are Shipped to

Employers by Chemical 

Manufacturers, Importers 

or Distributors

Implement the

Program

• All Employers receive 

labeled containers and 

safety data sheets with 

shipped chemicals

• All Employers must 

prepare a written 

hazard communication 

program, including a 

list of the hazardous 

chemicals in the 

workplace

Employers must ensure:

• All containers of 

hazardous chemicals 

are labeled

• Safety data sheets are 

maintained for all 

hazardous chemicals

• Workers are trained

on program elements, 

hazards, protective 

measures, etc.

Keep Information

Up-to-Date
4 Occupational Safety and Health Administration

In order to understand the requirements of 

HazCom 2012 as applied to your workplace, it 

is useful to have a general familiarity with the 

organization of the standard. It is divided into 

regulatory paragraphs that describe requirements, 

which are further supplemented by appendices 

that contain specific details.

Organization of the Regulatory Requirements 

for Hazard Communication

Paragraphs 

of the Standard

Appendices 

to the Standard

(a) Purpose

(b) Scope and 

Application

(c) Definitions

(d) Hazard Classification

(e) Written Hazard 

Communication Program

(f) Labels and Other 

Forms of Warning

(g) Safety Data Sheets

(h) Employee 

Information and Training

(i) Trade Secrets

(j) Effective Dates

Appendix A, Health 

Hazard Criteria 

(Mandatory) 

Appendix B, Physical 

Hazard Criteria 

(Mandatory) 

Appendix C, Allocation 

of Label Elements 

(Mandatory) 

Appendix D, Safety Data 

Sheets (Mandatory) 

Appendix E, Definition 

of “Trade Secret” 

(Mandatory)

Appendix F, 

Guidance for Hazard 

Classifications re: 

Carcinogenicity 

(Non-Mandatory) 

Under the HCS, an employer must prepare and 

implement a hazard communication program 

for workers potentially exposed to hazardous 

chemicals. The requirements most relevant to this 

responsibility can be found in paragraphs (e), (f), 

(g), and (h) as listed above and indicated in purple. 

The other parts of the standard may provide some 

guidance on understanding the requirements 

(such as Paragraph (c) Definitions), but your 

responsibilities are to employees in your workplace, 

and those responsibilities are specified in the 

standard paragraphs highlighted in the table above.

As previously mentioned, your suppliers must 

provide hazard information in the form of labels on 

containers and SDSs when you receive a chemical. 

The focus of the information is to provide the 

identities and hazards of the chemicals, their 

characteristics and properties, and how potential 

adverse effects can be prevented. A “hazardous 

chemical” means any chemical which is classified 

as a physical hazard or a health hazard, a simple 

asphyxiant, combustible dust, pyrophoric gas, or 

hazard not otherwise classified.

In addition to the health and physical hazards 

listed above, there may be some hazards that do 

not meet the specified criteria for the physical 

and health hazard classes provided in HazCom 

2012. In these cases, the chemical manufacturer or 

importer will designate the hazards as “hazards not 

otherwise classified” (HNOC), and must provide 

information on the SDS to ensure that downstream 

employers are aware of these other effects and any 

appropriate protective measures.

HCS Health and Physical Hazards

Health Hazards Physical Hazards

•	 Acute toxicity

•	 Skin corrosion/

irritation

•	 Serious eye damage/

eye irritation

•	 Respiratory or skin 

sensitization

•	 Germ cell 

mutagenicity

•	 Carcinogenicity

•	 Reproductive toxicity

•	 Specific target organ 

toxicity – single and 

repeated exposure

•	 Aspiration hazard

•	 Simple asphyxiant

•	 Explosives

•	 Flammable gases

•	 Flammable aerosols

•	 Oxidizing gases

•	 Gases under pressure 

•	 Flammable liquids

•	 Flammable solids

•	 Self-reactive chemicals

•	 Pyrophoric liquids

•	 Pyrophoric solids

•	 Pyrophoric gas

•	 Self-heating chemicals

•	 Chemicals which in 

contact with water, 

emit flammable gases

•	 Oxidizing liquids

•	 Oxidizing solids

•	 Organic peroxides

•	 Corrosive to metals

•	 Combustible dust
Hazard Communication: Small Entity Compliance Guide for Employers That Use Hazardous Chemicals 5

HazCom 2012 refers to each of the defined hazards 

as a “hazard class.” Most of these hazard classes 

are subsequently divided into one or more 

“hazard category(ies).” This classification is 

done by the chemical manufacturer or importer, 

and is based on the severity of the effect, and 

the type of data available to indicate each effect. 

This is important to employers because it leads 

directly to the information that is subsequently 

provided on labels and SDSs for the chemical. For 

example, there are four categories in the hazard 

class for flammable liquids. These categories 

are based primarily on flashpoints, so the lower 

the flashpoint, the more severe the effect. The 

warnings provided on labels will reflect this 

severity in different statements depending on 

which category the chemical falls into based on 

its flashpoint. The category itself does not appear 

on the label, but it is available on the SDS for the 

employer’s reference. As an example of hazard 

categories under HazCom 2012, the following is 

the criteria for categorizing chemicals classified as 

flammable liquids:

Criteria for Flammable Liquids

Category Criteria

1 Flash point < 23°C (73.4°F) and initial 

boiling point ≤ 35°C (95°F)

2 Flash point < 23°C (73.4°F) and initial 

boiling point > 35°C (95°F)

3 Flash point ≥ 23°C (73.4°F) and 

≤ 60°C (140°F)

4 Flash point > 60°C (140°F) and 

≤ 93°C (199.4°F)

As an employer who uses but does not 

manufacture or import chemicals, you are not 

responsible for making classifications or evaluating 

the hazards of a chemical. You must receive a 

label and SDS from your supplier based on the 

classification the supplier has made given the 

available scientific data on the product. All of the 

criteria used by the chemical manufacturer or 

importer to perform the classification are provided 

in HazCom 2012 in Appendices A and B.

Employers are allowed to perform their own 

classifications if they choose not to rely on the 

information provided by the chemical manufacturer 

or importer. If you choose to perform your own 

classification you will need to comply with the 

requirements in Appendices A and B of the standard.

If you choose to rely on the classification 

performed by the manufacturer or importer, it is 

not necessary to be familiar with the criteria for 

classifying the chemicals, or the scientific data 

supporting classification. However, you must 

have a basic understanding of the hazardous 

effects caused by the chemicals in your workplace. 

You must also have such an understanding in 

order to use the information to select protective 

measures, and ensure proper management of the 

chemicals in your workplace. Additionally, you 

must include information on the different types of 

hazards of the chemicals used in your workplace 

and how workers can protect themselves in your 

information and training program.

Compliance Dates

The first compliance date of importance is 

December 1, 2013. By that date, you must train 

your employees about the format and presentation 

of the new labels and SDSs they will be seeing 

in the workplace. Over the course of several 

years, your suppliers will be updating labels and 

SDSs to comply with the new requirements. It 

is, therefore, important to ensure that you and 

your employees are able to access and use the 

information provided in the new approach. All new 

labels and SDSs must be finished by June 1, 2015; 

however, if you order from a distributer you may 

still receive labels compliant with HazCom 1994 

(the hazard communication standard issued in 

1994 and replaced in 2012 by the revised standard) 

until December 1, 2015. If an employer identifies 

new hazards after December 1, 2015 due to the 

reclassification of the hazardous chemicals, it has 

six months, until June 1, 2016, to ensure that those 

hazards are included in the hazard communication 

program, workplace labeling reflects those 

new hazards, and employees are trained on 

the new hazards. During the transition from 

current requirements to the new requirements, 

employers may comply with either HazCom 1994 

or HazCom 2012, both of which require a hazard 

communication program. 
6 Occupational Safety and Health Administration

HazCom 2012 – Complete Schedule of Effective Dates

Effective Completion Date Requirement(s) Who

December 1, 2013 Train employees on the new label 

elements and SDS format.

Employers

June 1, 2015

December 1, 2015

Comply with all modified provisions of 

HazCom 2012, except: 

Distributors may ship products labeled 

by the manufacturer or importer under 

the old system until December 1, 2015.

Chemical manufacturers, importers, 

distributors and employers

June 1, 2016 Update alternative workplace labeling 

and hazard communication program 

as necessary, and provide additional 

employee training for newly-identified 

physical or health hazards.

Employers

Transition Period Comply with either HazCom 2012, 

HazCom 1994, or both.

All chemical manufacturers, importers, 

distributors and employers
Hazard Communication: Small Entity Compliance Guide for Employers That Use Hazardous Chemicals 7

II. STEPS TO AN EFFECTIVE 

HAZARD COMMUNICATION 

PROGRAM

All workplaces where workers are exposed to 

hazardous chemicals must have a written hazard 

communication program that describes how the 

HazCom standard is implemented in that facility. 

When hazard communication is implemented 

effectively, it has significant benefits for both 

the employer and the workers in a workplace. 

Employers need the information provided to them 

in order to assess the safety and health aspects 

of their workplace appropriately, and to select 

needed control measures for the chemicals that 

are present. The information provided on SDSs 

may also be used by employers to select the least 

hazardous chemical available to accomplish what 

is needed in the workplace. Substitution of a less 

hazardous chemical benefits workers because 

they will not be exposed to the greater hazards, 

and benefits employers because they may have 

less need for controls in some situations. The 

information employers receive on labels and SDSs 

will help them meet requirements for a safe and 

healthful workplace.

An effective hazard communication program 

benefits both workers and employers. The 

information provided by suppliers allows employers 

to design and implement a chemical safety and 

health management program.

Workers are entitled to the information about 

the identities and hazards of the chemicals 

they are potentially exposed to when working. 

When workers have such information, they are 

able to take steps to protect themselves, and 

to implement the controls their employer has 

selected for them. Knowing the health effects 

is important so that any signs or symptoms of 

exposure can be evaluated. Furthermore, being 

aware of the chemicals and associated hazards 

can help the worker determine how the exposure 

may affect preexisting medical conditions. 

In a survey conducted by the U.S. Government 

Accountability Office (GAO), approximately 30% 

of responding small businesses indicated they 

used information on SDSs to find less hazardous 

chemicals to use in their workplaces.

Some employers view hazard communication as 

merely a “paper exercise,” regarding compliance 

as just making sure that all the required labels and 

SDSs are available, but not using the information. 

Hazard communication is much more than a 

paper exercise when implemented properly. The 

proper use of the information by employers to 

control chemical exposure results in a decrease 

in illnesses and injuries caused by chemicals 

in the workplace—a clear benefit for exposed 

workers. Effective hazard communication also 

helps with effective management of chemicals in 

the workplace, resulting in increased productivity, 

decreased workers’ compensation costs, and other 

employer benefits. 

The HCS includes a three-part approach to 

communicating information to downstream 

employers, as well as workers. 

■ Labeling containers of hazardous chemicals, 

which serves as an immediate warning of 

hazards

■ SDSs, which are sources of detailed 

information on the hazardous chemical

■ Training on the hazards

An effective hazard communication program can 

be accomplished in six steps (Figure 2). 
8 Occupational Safety and Health Administration

Figure 2: Six Steps to an Effective Hazard Communication Program 

1. Learn the 

Standard/Identify 

Responsible Staff

•	 Obtain a copy of OSHA’s Hazard Communication Standard.

•	 Become familiar with its provisions.

•	 Make sure that someone has primary responsibility for 

coordinating implementation.

•	 Identify staff for particular activities (e.g., training).

2. Prepare and 

Implement a 

Written Hazard 

Communication 

Program

•	 Prepare a written plan to indicate how hazard 

communication will be addressed in your facility.

•	 Prepare a list or inventory of all hazardous chemicals in 

the workplace.

3. Ensure Containers 

are Labeled

•	 Keep labels on shipped containers.

•	 Label workplace containers where required.

4. Maintain Safety 

Data Sheets

•	 Maintain safety data sheets for each hazardous chemical in 

the workplace.

•	 Ensure that safety data sheets are readily accessible 

to employees.

5. Inform and Train 

Employees

•	 Train employees on the hazardous chemicals in their 

work area before initial assignment, and when new hazards 

are introduced.

•	 Include the requirements of the standard, hazards of 

chemicals, appropriate protective measures, and where and 

how to obtain additional information.

6. Evaluate and 

Reassess Your 

Program

•	 Review your hazard communication program periodically to 

make sure that it is still working and meeting its objectives.

•	 Revise your program as appropriate to address changed 

conditions in the workplace (e.g., new chemicals, new 

hazards, etc.).
Hazard Communication: Small Entity Compliance Guide for Employers That Use Hazardous Chemicals 9

1. Learn the 

Standard/Identify 

Responsible Staff

•	 Obtain a copy of OSHA’s Hazard Communication Standard.

•	 Become familiar with its provisions.

•	 Make sure that someone has primary responsibility for 

coordinating implementation.

•	 Identify staff for particular activities (e.g., training).

You are already on your way to accomplishing 

Step 1 by reading this guide. It is always best 

to review the actual provisions of the standard 

to ensure you are in full compliance. OSHA 

provides online access to the standard, as well 

as guidance, interpretations, and other relevant 

materials on its hazard communication web page: 

www.osha.gov/dsg/hazcom. The full regulatory 

text can be found at: www.osha.gov/dsg/hazcom/

HCSFinalRegTxt.html. 

As noted above, the provisions that apply 

to employers simply using chemicals in the 

workplace, rather than those that produce or 

import chemicals, are found primarily in the 

following paragraphs:

(e) Written Hazard Communication Program; 

(f) Labels and Other Forms of Warning; 

(g) Safety Data Sheets; and 

(h) Employee Information and Training. 

You can focus on the requirements in these 

paragraphs to determine what is needed for 

compliance in your workplace. There may also be 

other provisions of the standard that help establish 

compliance requirements in some workplaces. 

Paragraph (b), Scope and Application, specifies 

two types of work operations where the coverage 

of the rule is limited. These are laboratories 

and operations where chemicals are only 

handled in sealed containers (e.g., a warehouse). 

Employers with these types of work operations 

have reduced obligations under the HCS and 

basically only need to keep labels on containers 

as they are received; maintain SDSs that are 

received, and give employees access to them; and 

provide information and training to employees. 

Laboratories and operations where chemicals are 

only handled in sealed containers do not have to 

have written hazard communication programs and 

lists of chemicals.

The limited coverage for laboratories and sealed 

container operations addresses your obligation 

to your own workers in the operations involved. 

However, when laboratory employers or employers 

where only sealed containers are involved 

act as chemical manufacturers, distributors 

or importers, they must fulfill their duties as 

suppliers. For example, in warehouse operations 

where the employees are only exposed to sealed 

containers, paragraph (b)(4) of the standard would 

apply. When these chemicals are distributed to 

downstream users, paragraph (b)(4) requires the 

company to provide HazCom 2012-compliant labels 

and SDSs to downstream customers at the time of 

the first shipment and when the SDS is updated. 

Paragraph (c), Definitions, can be used to 

determine the meaning of some provisions in 

HazCom 2012 through the definitions provided for 

the terms used in them. This guide will highlight 

some of these definitions, but you may want to 

consult the definitions for other terms to help 

ensure you fully understand your compliance 

obligations in the workplace.

Hazard communication must be a continuing 

program in your facility. Compliance with the 

HCS is not a “one shot deal.” In order to have 

a successful program, it will be necessary to 

assign responsibility to staff for both the initial 

and ongoing activities needed to comply with 

the standard. In some cases, these activities may 

already be part of current job assignments. For 

example, site supervisors are frequently responsible 
10 Occupational Safety and Health Administration

for on-the-job training sessions. Early identification 

of the responsible workers, and their involvement in 

the development of your plan of action, will result in 

a more effective program design. 

In order to ensure you have an effective 

program and address all of the necessary 

components, responsibility for implementation 

of hazard communication should be assigned 

to someone to coordinate. While different 

people may be responsible for certain parts 

of implementation, there should nevertheless 

be someone who has overall responsibility. 

Approaching compliance consistently, and 

comprehensively, is the key to success.

The person responsible for the overall coordination 

may not be the best person to accomplish all 

of the elements. For example, training workers 

may require different expertise than coordinating 

compliance. The standard allows employers the 

flexibility to do what is best in their own facilities as 

long as compliance with all elements is achieved.
Hazard Communication: Small Entity Compliance Guide for Employers That Use Hazardous Chemicals 11

2. Prepare and 

Implement a 

Written Hazard 

Communication 

Program

•	 Prepare a written plan to indicate how hazard 

communication will be addressed in your facility.

•	 Prepare a list or inventory of all hazardous chemicals in 

the workplace.

Paragraph (e), Written Hazard Communication 

Program, requires employers to prepare and 

implement a written hazard communication 

program. This does not need to be lengthy or 

complicated. The main intent of the requirement is 

to help ensure that compliance with the standard 

is done in a systematic way and that all elements 

are coordinated. Thus, the program must describe 

how the employer will address the requirements 

of paragraphs (f) Labels and Other Forms of 

Warning; (g) Safety Data Sheets; and (h) Employee 

Information and Training, in the workplace. A 

sample written program is provided in Appendix A 

of this guide.

In addition, the written program must include the 

following items:

■ Paragraph (e)(1): A list of the hazardous 

chemicals known to be present in the 

workplace. The list may be kept using any 

product identifier from the SDS. Thus, the list 

may be kept by product name, common name, 

or chemical name. The important aspect of 

this requirement is that the term used on the 

list must also be available on both the SDS 

and the label so that these documents can be 

cross-referenced. The list can be compiled in 

whatever way the employer finds most useful 

and applicable to the workplace. A list of all 

hazardous chemicals in the entire workplace 

may be most suitable for very small facilities, 

where there are few work areas and all 

workers are potentially exposed to essentially 

the same products. For larger workplaces, it 

may be more convenient to compile lists of 

hazardous chemicals by work area and have 

them assembled together as the overall list for 

the workplace. 

The list is an inventory of chemicals for which 

the employer must ensure that there is an 

SDS available. Compiling the list also helps 

employers keep track of the chemicals present, 

and to identify chemicals that are no longer 

being used, and thus could be removed from 

the workplace. Removing such chemicals may 

also reduce potential adverse effects that could 

occur in the workplace.

The best way to prepare a comprehensive list 

may be to survey the workplace. Purchasing 

records may also help and employers should 

establish procedures to ensure that purchasing 

procedures result in receiving SDSs before 

a material is used in the workplace. Prior to 

purchasing chemicals, review the hazards of 

the chemicals and evaluate if less hazardous 

chemicals can be used instead.

“Product identifier” means the name or number 

used for a hazardous chemical on a label or in 

the SDS. It provides a unique means by which 

the user can identify the chemical. The product 

identifier used shall permit cross-references to 

be made among the list of hazardous chemicals 

required in the written hazard communication 

program, the label and the SDS.

The broadest possible perspective should 

be taken when doing the survey. Sometimes 

people think of “chemicals” as being only 

liquids in containers. The HCS covers 

chemicals in all forms—liquids, solids, gases, 

vapors, fumes, and mists—whether they are 

“contained” or not. The hazardous nature of 

the chemical and the potential for exposure are 
12 Occupational Safety and Health Administration

the factors that determine whether a chemical 

is covered. If the chemical is not hazardous, it 

is not covered by the standard. If there is no 

potential for exposure (e.g., the chemical is 

inextricably bound and cannot be released), the 

chemical is not covered by the standard.

Look around. Identify chemicals in containers, 

including pipes, but also think about chemicals 

that are generated during work operations. For 

example, welding fumes, dusts, and exhaust 

fumes are all sources of chemical exposures. 

Read the labels provided by suppliers for hazard 

information. Make a list of all chemicals in the 

workplace that are potentially hazardous. For 

your own information and planning, you may 

also want to note on the list the location(s) of the 

products within the workplace, and an indication 

of the hazards as found on the label. This will 

help as you prepare the rest of your program.

Paragraph (b) of the standard, scope and 

application, includes exemptions for various 

chemicals or workplace situations. After 

compiling the complete list of chemicals, you 

should review paragraph (b) to determine if 

any of the items can be eliminated from the 

list because they are exempted materials. For 

example, food, drugs, and cosmetics brought 

into the workplace for personal consumption 

by workers are exempt. 

Once you have compiled a complete list of 

the potentially hazardous chemicals in the 

workplace, the next step is to determine if 

you have received SDSs for all of them. Check 

your files against the inventory you have just 

compiled. Employers are required to have 

SDSs for all hazardous chemicals that they 

use. If any are missing, contact your supplier 

and request one. It is a good idea to document 

these requests, either by keeping a copy of a 

letter or e-mail, or a note regarding telephone 

conversations. If you cannot show a good faith 

effort to receive the SDS, you can be cited for 

not having the SDS for a hazardous chemical. 

If you have SDSs for chemicals that are not on 

your list, figure out why. Maybe you do not use 

the chemical anymore. Or maybe you missed 

it in your survey. Some suppliers provide 

SDSs for products that are not hazardous. 

These SDSs do not have to be maintained.

Do not allow workers to use any hazardous 

chemicals for which you have not received an 

SDS. The SDS provides information you need 

to ensure that proper protective measures are 

implemented prior to worker exposure.

■ Paragraph (e)(1)(ii): Methods to inform 

employees of the hazards of non-routine tasks. 

The written program needs to include how 

an employer will inform workers of hazards 

that are outside of their normal work routine. 

While workers’ initial training will address the 

types of exposures they will encounter in their 

usual work routines, there may be other tasks 

to be performed on occasion that will expose 

these workers to different hazards, as well as 

require novel control measures. For example, 

in a manufacturing facility, it may be necessary 

periodically to drain and clean out reactor 

vessels. For this task, workers may be exposed 

to cleaning chemicals that are not normally in 

the workplace, and the usual controls for the 

process may not protect them, so personal 

protective equipment may have to be worn. 

The written program needs to address how the 

employer will handle such situations and make 

sure that workers involved have the necessary 

information to stay protected.

■ Paragraph (e)(2): Multi-Employer Workplaces.

Where there is more than one employer 

operating on a site, and employees may 

be exposed to the chemicals used by each 

employer, the employer’s written hazard 

communication program must address:

— How on-site access to SDSs will be 

provided to the other employer(s).

— How such employers will be informed of 

needed precautionary measures.

— How such employers will be informed of 

the on-site labeling system if it is different 

from the labels specified for shipped 

containers under the standard.
Hazard Communication: Small Entity Compliance Guide for Employers That Use Hazardous Chemicals 13

In summary, if you are not a new employer, 

you should already have a written hazard 

communication program for your workplace. 

Review your written program to ensure that it is 

consistent with the HazCom 2012 requirements. 

It may need to be updated; for example, you may 

have to add or delete chemicals from the list in 

the program, or change your description of the 

approach to workplace labeling.

If your workers’ job assignment requires travel 

between various geographical locations, you 

may keep the written program at the primary 

work location. 

Many trade associations and other professional 

groups have provided sample programs and 

other assistance materials to employers. These 

have been very helpful to many employers since 

they tend to be tailored to the particular industry 

involved. You may wish to investigate whether 

your industry trade groups have developed such 

materials. Additionally, a sample written hazard 

communication program is included in Appendix A 

to this guide.

Although such general guidance may be helpful, 

you must remember that the written program has 

to reflect what you are doing in your workplace. 

Therefore, if you use a generic program it must 

be adapted to address the facility that it actually 

covers. For example, the written plan must list 

the chemicals present at the site, indicate who is 

to be responsible for the various aspects of the 

program in your facility, and indicate where written 

materials will be made available to workers.

If OSHA inspects your workplace, the OSHA 

Compliance Safety and Health Officer (CSHO) will 

ask to see your written plan. 
14 Occupational Safety and Health Administration

3. Ensure Containers 

are Labeled

•	 Keep labels on shipped containers.

•	 Label workplace containers where required.

Labels are the first part (paragraph (f) Labels and 

Other Forms of Warning) of the three-part approach 

to communicating information downstream 

mentioned earlier. A label must be on the 

immediate container of every hazardous chemical. 

The label is an immediate type of warning since 

it is present in the work area, right on the actual 

container of a hazardous chemical. It is a snapshot 

of the hazards and protective information related to 

the chemical, and a summary of the more detailed 

information available on the SDS.

When you purchase a hazardous chemical from a 

supplier, you will receive a container that is labeled 

with the information required under the HCS. 

Employers can rely on the information provided 

by their suppliers. The label requirements in the 

HCS changed significantly with the publication of 

HazCom 2012. Under the prior standard, chemical 

manufacturers and importers were required to 

convey the hazards and identity of the products, 

but were not given specifications on how this 

was to be done. As a result, labels varied in 

terms of how the information was conveyed, the 

terminology used, and the design of the label. This 

made it more difficult for employers and workers 

to access and comprehend the information 

presented than if chemical manufacturers and 

importers follow the same approach.

The label requirements for the revised standard 

are more specific, which will lead to increased 

uniformity. This should benefit employers 

and workers by providing the information in 

standardized language and graphics, making it 

easier to understand, and helping to ensure that 

labels on containers of the same chemical from 

different suppliers have the same information.

HazCom 2012 provides chemical manufacturers 

and importers the information to be conveyed 

once they have determined the hazard of a 

chemical. The labels you receive on a shipped 

container must have the following information, 

located together (other information may also 

appear on the label):

■ Product identifier

■ Signal word

■ Hazard statement(s)

■ Pictogram(s)

■ Precautionary statement(s)

■ Name, address, and phone number of the 

responsible party

■ The product identifier is any chemical, 

common, or trade name or designation that the 

chemical manufacturer or importer chooses to 

use on the label. The term must also appear on 

the SDS. The signal word, hazard statement(s), 

pictogram(s), and precautionary statement(s) 

are the label elements that comprise the 

primary information about hazards and 

protective measures on the label.

■ A signal word is a word used to indicate the 

relative level of severity of hazard and alert the 

reader to a potential hazard on the label. The 

signal words used in the standard are “danger”

and “warning.” “Danger” is used for the more 

severe hazards, while “warning” is used for 

the less severe hazards. Signal words were not 

previously used in the HCS, although they do 

often appear on consumer labels. It is important 

to be aware of—and train workers on—the way 

signal words convey a difference in the severity 

of the hazard. While the product is hazardous 

wherever a signal word is indicated, the signal 

word chosen can give a preliminary idea of the 

relative significance of the effect.

■ A hazard statement is a statement assigned to 

a hazard class and category that describes the 

nature of the hazard(s) of a chemical, including, 

where appropriate, the degree of hazard. 

Example: Fatal if swallowed.
Hazard Communication: Small Entity Compliance Guide for Employers That Use Hazardous Chemicals 15

■ The hazard statement(s) for a hazardous 

chemical describe the hazard(s) in text, in 

a simple, direct manner. There is a hazard 

statement for each hazard category of a hazard 

class, and it will vary depending on the degree 

of hazard. The example presented above is a 

hazard statement for acute oral toxicity. The 

hazard statement conveys that the chemical is 

severely toxic, and ingestion of the chemical 

results in death. But for less toxic chemicals, 

the hazard statement may be “toxic if 

swallowed” or “harmful if swallowed.” As with 

the signal words, this information conveys the 

relative severity of the hazard, which impacts 

how it is handled and controlled.

■ A pictogram is a composition that may include 

a symbol plus other graphic elements, such as 

a border, background pattern, or color, that is 

intended to convey specific information about 

the hazards of a chemical. Eight pictograms are 

designated under this standard for application 

to a hazard category. Under HazCom 2012, 

pictograms are black symbols, on a white 

background, with a red diamond border. For 

example, this is the pictogram for oxidizers:

Pictograms are an important addition to the 

hazard communication tools in the standard. 

A pictogram draws the attention of a label 

reader, and you and your workers should be 

aware that the appearance of a pictogram in 

a red diamond frame means that a hazard of 

concern is present in the product. Some of the 

pictograms in the standard have symbols that 

resemble the hazardous effect, and others are 

merely meant to attract attention. Pictograms 

may be used for several different hazardous 

effects as well (see Figure 3).

Pictograms have long been used internationally 

because they convey information without text. 

This allows users who are either literate in a 

different language than that used on the label 

or who are not literate at all to understand that 

the chemical is hazardous. 

One of the systems that has long used 

pictograms is the international transport 

system. This system has been adopted by 

the U.S. Department of Transportation (DOT), 

and is familiar to those who handle shipping 

containers in the United States. The symbols 

have been harmonized as much as possible 

for the hazards covered both in transport 

and in the workplace. While both pictograms 

are diamond-shaped, the transport system’s 

pictograms have backgrounds of various 

colors. Where the shipping container is also the 

container used in the workplace, workers must 

be made aware of the DOT pictograms1, as 

they may appear on the label in addition to, or 

instead of, the HazCom 2012 pictograms used 

to represent the same hazard. See Figure 4 for 

examples of DOT pictograms. Note that the 

environment pictogram located in the center 

of the bottom row in Figure 3 is not required 

under the OSHA standard since OSHA does 

not regulate environmental hazards. However, 

you may see this pictogram used on labels and 

SDSs to convey environmental hazards, and 

that will provide useful information for you to 

use in managing your chemicals.

1. The U.S. Department of Transportation (DOT) uses the terms transport 

“placards” or “labels” to refer to the diamond-shaped (square on point) 

graphic elements that are used to identify shipments of hazardous materials. However, for the purpose of this document, these graphic elements 

are referred to as “pictograms.” More information on DOT placards or 

labels may be found at www.dot.gov.
16 Occupational Safety and Health Administration

Figure 3: HazCom 2012 Pictograms
Hazard Communication: Small Entity Compliance Guide for Employers That Use Hazardous Chemicals 17

Figure 4: Examples of Transport Pictograms
18 Occupational Safety and Health Administration

■ A precautionary statement is a phrase that 

describes recommended measures that should 

be taken to minimize or prevent adverse 

effects resulting from exposure to a hazardous 

chemical, or improper storage or handling. 

Example: Do not eat, drink, or smoke when 

using this product.

Precautionary statements are key to helping you 

decide what you need to do to protect workers 

and your workplace. There are four types of 

statements: Prevention, Response, Storage, and 

Disposal. These have been assigned to hazard 

classes and categories.

Therefore, a compliant HazCom 2012 label on a 

shipped container will have at least the following 

information as shown in Figure 5 (supplemental 

information is permitted as long as it does not 

conflict with the required information).

You are required by paragraph (f)(6) of the 

standard to ensure that containers of hazardous 

chemicals in your workplace are labeled. For those 

containers that are received already labeled from 

the supplier, and are used in the workplace, simply 

maintaining the label received from the supplier is 

the best and easiest option. However, the standard 

is flexible, and employers may relabel these 

containers, or label other containers used in the 

workplace with various options as long as workers 

have immediate access to the specific information 

about the physical and health hazards of the 

chemical. This could be included in the workplace 

hazard communication program. 

Under paragraph (f)(7), employers may use signs, 

placards, process sheets, batch tickets, operating 

procedures, or other written material instead of 

affixing labels to individual stationary process 

containers, as long as the alternative method 

identifies which containers it applies to and conveys 

at least general information regarding the hazards 

of the chemicals. Paragraph (f)(8) of the standard 

also addresses portable containers into which the 

hazardous chemicals are transferred from a labeled 

container, and which are for the immediate use of 

the employee who performs the transfer. These 

portable containers do not have to be labeled.

Figure 5: Example of Required HCS Label Elements

Product Identifier

Pictogram (Symbol in Red Frame)

Signal Word (Danger)

Hazard Statement(s) (Extremely flammable gas)

Precautionary Statement(s) (Keep away from heat and open flames. No smoking. 

Leaking gas fire: Do not extinguish, unless leak can be stopped safely. Eliminate all ignition 

sources if safe to do so. Store in well-ventilated place.)

Name, Address, and Telephone Number

of Manufacturer, Importer, or Other Responsible Party
Hazard Communication: Small Entity Compliance Guide for Employers That Use Hazardous Chemicals 19

Some employers use third-party workplace label 

systems, such as those that have numerical 

ratings to indicate the hazards (e.g., National 

Fire Protection Association (NFPA) or Hazardous 

Materials Identification System (HMIS)). These 

may be used in conjunction with the supplemental 

information on the label to ensure that workers 

have complete information, as long as the ratings 

are consistent with the hazard definitions in 

HazCom 2012, i.e., the criteria used to assign the 

numerical ratings reflects the hazard categories 

in each hazard class in HazCom 2012. One note 

with regard to numerical ratings—these systems 

generally use the number 1 to indicate the lowest 

degree of hazard, and the number 4 as the highest 

degree. This is the opposite of the hazard category 

numbering in HazCom 2012. Therefore, if as an 

employer you are preparing such labels based 

on information on the SDS, you must ensure that 

the numbers are properly applied to reflect the 

accurate degree of hazard information. Category 

numbers do not appear on HazCom 2012 shipped 

container labels, and are not equivalent to the 

hazard rating systems. 

HazCom 2012 hazard category numbers are not 

required to appear on shipped container labels, and 

are not equivalent to the NFPA and HMIS hazard 

rating systems. 

The employer must make sure that labels in the 

workplace are legible and prominently displayed. 

While the label information must be in English, 

employers are free to add warnings in other 

languages if workers would find that helpful. OSHA 

has prepared QuickCardsTM to describe the label 

elements (OSHA 3492), as well as illustrate the 

pictograms (OSHA 3491). These are available on 

the OSHA web page, or can be obtained from your 

local OSHA area office.

If your workplace is inspected by OSHA, CSHOs 

will be looking for at least the following aspects of 

your labeling approach:

1. Designation of person(s) responsible for 

ensuring compliant labeling of shipped and inplant containers;

2. Description of written alternatives to labeling of 

stationary process containers (if used); 

3. Appropriate labels on all workplace containers, 

including those received from a supplier, 

secondary containers, and stationary process 

containers; 

4. A description and explanation of labels on both 

shipped and workplace containers included in 

the employee training program; and,

5. Procedures to review and update workplace 

label information when necessary.
20 Occupational Safety and Health Administration

4. Maintain Safety 

Data Sheets

•	 Maintain safety data sheets for each hazardous chemical in 

the workplace.

•	 Ensure that safety data sheets are readily accessible 

to employees.

The second part in the approach to communicating 

information in HazCom 2012 is to maintain 

SDSs (paragraph (g) Safety Data Sheets and 

Mandatory Appendix D). The SDSs are the source 

of detailed information on hazardous chemicals. 

This includes information for many different 

audiences—employers, workers, safety and 

health professionals, emergency responders, 

government agencies, and consumers. It is difficult 

for one document to serve the needs of all of these 

different audiences since some require much 

more technical information than others. Therefore, 

the SDS sections have generally been organized 

so that the information of most use to exposed 

workers, emergency responders, and others who 

do not need extensive technical detail is in the 

beginning of the SDS, while the more technical 

information most commonly read by health and 

safety professionals is located in the later sections. 

For example, a description of a chemical’s health 

effects appears in Section 2, hazard identification, 

but the toxicological data upon which the 

determination of these effects is based appears 

in Section 11, toxicological information. All of the 

sections are available to any reader, but there 

is a difference between what is necessary for 

a broader audience (workers and emergency 

responders, for example), and what might be 

needed by others designing protective measures 

or providing medical services. 

The SDS requirements in HazCom 2012 are based 

on an internationally agreed upon 16-section SDS. 

This format is based on ANSI Z400.12, so it 

2 The first American National Standard Institute (ANSI) standard developed 

to assist in the preparation of safety data sheets (American National 

Standard for Hazardous Industrial Chemicals–Material Safety Data Sheets–

Preparation) was issued in 1993. This standard was updated in 1998 and 

2004. In 2010, it was combined with ANSI Z129 and renamed, American 

National Standard for Hazardous Workplace Chemicals–Hazard Evaluation 

and Safety Data Sheet and Precautionary Labeling Preparation.

is most likely already familiar to your employees. 

HazCom 2012 establishes section headings for the 

SDS, as well as the order in which they are to be 

provided, and the minimum information required 

to be included in each section under Appendix D 

of the standard. However, the information in some 

of the sections are non-mandatory because they 

address information that involve the requirements 

of other government bodies, and thus are not 

under OSHA’s jurisdiction. Even though these 

sections are not considered mandatory by OSHA, 

the headings are still required to be present on the 

SDS. They will provide useful information for you 

to address other requirements you may need to 

follow. The sixteen sections are as follows, with 

the non-mandatory sections indicated in italics:

1. Identification

2. Hazard(s) identification

3. Composition/information on ingredients

4. First-aid measures

5. Firefighting measures

6. Accidental release measures

7. Handling and storage

8. Exposure control/personal protection

9. Physical and chemical properties

10. Stability and reactivity

11. Toxicological information

12. Ecological information

13. Disposal considerations

14. Transport information

15. Regulatory information

16. Other information 

Chemical manufacturers and importers are 

required to obtain or develop an SDS for each 

hazardous chemical they produce or import. 

Chemical manufacturers, importers, and 
Hazard Communication: Small Entity Compliance Guide for Employers That Use Hazardous Chemicals 21

distributors are responsible for ensuring that their 

customers are provided a copy of these SDSs, at 

the time of the first shipment, and when an SDS 

is updated with new and significant information. 

Employers must have an SDS for each hazardous 

chemical which they use. Employers may rely 

on the information received from their suppliers 

unless they know the information is incorrect. 

If you do not receive an SDS automatically, you 

must request one as soon as possible. If you 

receive an SDS that is obviously inadequate, with, 

for example, blank spaces, you must request an 

appropriately completed one. If your request for 

an SDS or for a corrected SDS does not produce 

the information needed, you should contact your 

local OSHA area office for assistance in obtaining 

the SDS. Employers must maintain the current 

version of the SDS; if a new SDS is received with a 

shipment, they must maintain and make available 

the new SDS.

The SDSs must be in English. Many larger 

manufacturers also produce SDSs in other 

languages. If you have workers who speak 

language(s) other than English, you may be able to 

obtain SDSs in those languages to ensure effective 

hazard communication.

Employers must maintain copies of SDSs in their 

workplaces, and must ensure that SDSs are readily 

accessible to workers when they are in their work 

areas during their work shifts. This accessibility 

may be accomplished in many different ways. You 

must decide what is appropriate for your particular 

workplace. Some employers keep the SDSs in 

a binder in a central location (e.g., in a pick-up 

truck on a construction site). Others, particularly 

in workplaces with large numbers of chemicals, 

provide access electronically. However, if access 

to SDSs is provided electronically, there must 

be an adequate back-up system in place in the 

event of a power outage, equipment failure, or 

other emergency involving the primary electronic 

system. As long as workers can get the information 

when they need it, any approach may be used. 

When workers must travel between workplaces 

during a work shift, SDSs may be kept at the 

primary workplace facility. No matter what system 

is used, employers must ensure that workers and 

medical personnel can immediately obtain the 

required information in an emergency.

In order to ensure that you have a current SDS for 

each chemical in the plant as required, and that 

worker access is provided, OSHA’s CSHOs will be 

looking for the following items in your program:

1. Designation of person(s) responsible for 

obtaining and maintaining the SDSs;

2. How such sheets are maintained in the 

workplace (e.g., in notebooks in the work 

area(s) or electronically), and how workers 

obtain access to them when they are in their 

work area during the work shift;

3. Procedures to follow when the SDS is not 

received at the time of the first shipment;

4. An SDS for each hazardous chemical in 

the workplace, and training of workers that 

includes review of SDS format and use.

For employers using hazardous chemicals, an 

important aspect of the hazard communication 

program is to ensure that someone is responsible 

for obtaining and maintaining the SDSs for 

every hazardous chemical in the workplace. To 

ensure that your hazard communication program 

improves safety and health with regard to 

chemical use, you should review the SDSs, and use 

the information to choose the needed protective 

measures to prevent or reduce exposures in your 

workplace. SDSs should be used to evaluate your 

workplace, and establish a plan to ensure it is safe. 

The following is a section-by-section description of 

the information required for each part of the SDS 

from Appendix D of HazCom 2012. Become familiar 

with the information available in each section of an 

SDS so that you will be able to more quickly access 

this information in an emergency and make better 

use of the data available.

OSHA has developed a QuickCardTM on SDSs 

(OSHA 3493) that may be useful in your training 

program. It is available on the OSHA Hazard 

Communication web page at www.osha.gov/dsg/

hazcom, or from your local OSHA area office.
2 2 Occupational Safety and Health Administration

Minimum Information for an SDS

Heading Subheading

1. Identification (a) Product identifier used on the label;

(b) Other means of identification; 

(c) Recommended use of the chemical and restrictions on use;

(d) Name, address, and telephone number of the chemical manufacturer, importer, or other 

responsible party;

(e) Emergency phone number.

2. Hazard(s) 

identification

(a) Classification of the chemical in accordance with paragraph (d) of §1910.1200;

(b) Signal word, hazard statement(s), symbol(s) and precautionary statement(s) in accord with 

paragraph (f) of §1910.1200. (Hazard symbols may be provided as graphical reproductions 

in black and white or the name of the symbol, e.g., flame, skull and crossbones);

(c) Describe any hazards not otherwise classified that have been identified during the 

classification process;

(d) Where an ingredient with unknown acute toxicity is used in a mixture at a concentration 

≥ 1% and the mixture is not classified based on testing of the mixture as a whole, a 

statement that X% of the mixture consists of ingredient(s) of unknown acute toxicity is 

required. 

3. Composition/ 

information on 

ingredients 

Except as provided for in paragraph (i) of §1910.1200 on trade secrets:

For Substances

(a) Chemical name;

(b) Common name and synonyms;

(c) CAS number and other unique identifiers;

(d) Impurities and stabilizing additives which are themselves classified and which contribute 

to the classification of the substance.

For Mixtures

In addition to the information required for substances: 

(a) The chemical name and concentration (exact percentage) or concentration ranges of all 

ingredients which are classified as health hazards in accordance with paragraph (d) of 

§1910.1200 and 

(1) are present above their cut-off/concentration limits; or

(2) present a health risk below the cut-off/concentration limits.

(b) The concentration (exact percentage) shall be specified unless a trade secret claim is made 

in accordance with paragraph (i) of §1910.1200, when there is batch-to-batch variability in 

the production of a mixture, or for a group of substantially similar mixtures (See A.0.5.1.2) 

with similar chemical composition. In these cases, concentration ranges may be used.

For All Chemicals Where a Trade Secret is Claimed

Where a trade secret is claimed in accordance with paragraph (i) of §1910.1200, a statement 

that the specific chemical identity and/or exact percentage (concentration) of composition has 

been withheld as a trade secret is required.
Hazard Communication: Small Entity Compliance Guide for Employers That Use Hazardous Chemicals 2 3

Heading Subheading

4. First-aid 

measures 

(a) Description of necessary measures, subdivided according to the different routes of 

exposure, i.e., inhalation, skin and eye contact, and ingestion;

(b) Most important symptoms/effects, acute and delayed;

(c) Indication of immediate medical attention and special treatment needed, if necessary.

5. Firefighting 

measures

(a) Suitable (and unsuitable) extinguishing media;

(b) Specific hazards arising from the chemical (e.g., nature of any hazardous combustion 

products);

(c) Special protective equipment and precautions for firefighters.

6. Accidental 

release measures

(a) Personal precautions, protective equipment, and emergency procedures;

(b) Methods and materials for containment and cleaning up.

7. Handling and 

storage 

(a) Precautions for safe handling;

(b) Conditions for safe storage, including any incompatibilities.

8. Exposure 

controls/

personal 

protection

(a) OSHA permissible exposure limit (PEL), American Conference of Governmental Industrial 

Hygienists (ACGIH) Threshold Limit Value (TLV), and any other exposure limit used or 

recommended by the chemical manufacturer, importer, or employer preparing the safety 

data sheet, where available;

(b) Appropriate engineering controls;

(c) Individual protection measures, such as personal protective equipment.

9. Physical and 

chemical 

properties

(a) Appearance (physical state, color, etc.);

(b) Odor;

(c) Odor threshold;

(d) pH;

(e) Melting point/freezing point;

(f) Initial boiling point and boiling range;

(g) Flash point;

(h) Evaporation rate;

(i) Flammability (solid, gas);

(j) Upper/lower flammability or explosive limits;

(k) Vapor pressure;

(l) Vapor density;

(m) Relative density;

(n) Solubility(ies);

(o) Partition coefficient: n-octanol/water;

(p) Auto-ignition temperature;

(q) Decomposition temperature;

(r) Viscosity.
24 Occupational Safety and Health Administration

Heading Subheading

10. Stability and 

reactivity

(a) Reactivity;

(b) Chemical stability;

(c) Possibility of hazardous reactions; 

(d) Conditions to avoid (e.g., static discharge, shock, or vibration);

(e) Incompatible materials;

(f) Hazardous decomposition products.

11. Toxicological 

information

Description of the various toxicological (health) effects and the available data used to identify 

those effects, including:

(a) Information on the likely routes of exposure (inhalation, ingestion, skin and eye contact);

(b) Symptoms related to the physical, chemical and toxicological characteristics; 

(c) Delayed and immediate effects and also chronic effects from short- and long-term exposure; 

(d) Numerical measures of toxicity (such as acute toxicity estimates);

(e) Whether the hazardous chemical is listed in the National Toxicology Program (NTP) Report on 

Carcinogens (latest edition) or has been found to be a potential carcinogen in the International 

Agency for Research on Cancer (IARC) Monographs (latest edition), or by OSHA.

12. Ecological 

information

(Nonmandatory)

(a) Ecotoxicity (aquatic and terrestrial, where available);

(b) Persistence and degradability;

(c) Bioaccumulative potential;

(d) Mobility in soil;

(e) Other adverse effects (such as hazardous to the ozone layer).

13. Disposal 

considerations 

(Nonmandatory)

Description of waste residues and information on their safe handling and methods of disposal, 

including the disposal of any contaminated packaging. 

14. Transport 

information 

(Nonmandatory)

(a) UN number;

(b) UN proper shipping name;

(c) Transport hazard class(es);

(d) Packing group, if applicable;

(e) Environmental hazards (e.g., Marine pollutant (Yes/No));

(f) Transport in bulk (according to Annex II of MARPOL 73/78 and the IBC Code); 

(g) Special precautions which a user needs to be aware of, or needs to comply with, in 

connection with transport or conveyance either within or outside their premises.

15. Regulatory 

information 

(Nonmandatory)

Safety, health and environmental regulations specific for the product in question.

16. Other 

information, 

including date 

of preparation 

or last revision

The date of preparation of the SDS or the last change to it.
Hazard Communication: Small Entity Compliance Guide for Employers That Use Hazardous Chemicals 25

5. Inform and Train 

Employees

•	 Train employees on the hazardous chemicals in their 

work area before initial assignment, and when new hazards 

are introduced.

•	 Include the requirements of the standard, hazards of 

chemicals, appropriate protective measures, and where and 

how to obtain additional information.

The third part of the hazard communication approach 

in HazCom 2012 is employee information and training 

(paragraph (h) Employee Information and Training). 

The key requirement is in paragraph (h)(1):

(h)(1) Employers shall provide employees with 

effective information and training on hazardous 

chemicals in their work area at the time of their 

initial assignment, and whenever a new chemical 

hazard the employees have not previously been 

trained about is introduced into their work area. 

Information and training may be designed to 

cover categories of hazards (e.g., flammability, 

carcinogenicity) or specific chemicals. Chemicalspecific information must always be available 

through labels and safety data sheets.

For information and training to be effective, the 

workers in the training must comprehend the 

hazards in the workplace and ways to protect 

themselves. OSHA does not expect that workers 

will be able to recall and recite all data provided 

about each hazardous chemical in the workplace. 

What is most important is that workers understand 

that they are exposed to hazardous chemicals, 

know how to read labels and SDSs, and have a 

general understanding of what information is 

provided in these documents, and how to access 

these tools. Workers must also be aware of the 

protective measures available in their workplace, 

how to use or implement these measures, and who 

they should contact if an issue arises. 

Information and training may be done either by 

individual chemical, or by hazard classes and 

categories (such as acute toxicity or flammable 

liquids). If there are only a few chemicals in the 

workplace, then you may want to discuss each 

one individually. Where there are large numbers of 

chemicals, or the chemicals change frequently, you 

will probably want to train generally based on the 

hazard classes and categories. Workers must have 

access to the substance-specific information on 

the labels and SDSs.

HazCom 2012 requires employers to both provide 

certain information to employees and to train 

employees. The standard requires employees to be 

informed of:

■ The general requirements of the Hazard 

Communication Standard;

■ Where hazardous chemicals are located in their 

work areas (operations where exposure may 

occur); and,

■ What the workplace hazard communication 

program includes, and where and how they can 

access the program.

Training, on the other hand, is a more active 

process. The training conducted to comply with 

HazCom 2012 must address the following:

■ Methods and observations that may be used to 

detect the presence or release of a hazardous 

chemical in the work area (such as monitoring 

conducted by the employer, continuous 

monitoring devices, visual appearance or odor of 

hazardous chemicals when being released, etc.);

■ The physical, health, simple asphyxiation, 

combustible dust and pyrophoric gas hazards, 

as well as hazards not otherwise classified, of 

the chemicals in the work area;

■ The measures employees can take to protect 

themselves from these hazards, including 

specific procedures the employer has 

implemented to protect employees from 
26 Occupational Safety and Health Administration

exposure to hazardous chemicals, such 

as appropriate work practices, emergency 

procedures, and personal protective equipment 

to be used; and,

■ The details of the hazard communication 

program developed by the employer, including 

an explanation of the labels received on 

shipped containers and the workplace labeling 

system used by their employer; the SDS, 

including the format of the SDS (where each 

type of information is located) and how 

employees can obtain and use the appropriate 

hazard information.

A properly conducted training program will ensure 

worker comprehension and understanding. It is 

not sufficient to either just read material to the 

workers, or simply hand them material to read. 

As explained in Dr. Michaels’ OSHA Training 

Standards Policy Statement (April 28, 2010), OSHA 

requires employers to present information in a 

manner and language that their employees can 

understand. If employers customarily need to 

communicate work instructions or other workplace 

information to employees in a language other than 

English, they will also need to provide safety and 

health training to employees in the same manner. 

Similarly, if the employee’s vocabulary is limited, 

the training must account for that limitation. By the 

same token, if employees are not literate, telling 

them to read training materials will not satisfy the 

employer’s training obligation. 

In conducting a training program, you want to 

create a climate where workers feel free to ask 

questions. This will help you to ensure that the 

information is understood. You must always 

remember that the underlying purpose of the 

HCS is to reduce the incidence of chemical source 

illnesses and injuries. This will be accomplished by 

modifying behavior through the provision of hazard 

information and information about protective 

measures. If your program works, you and your 

workers will better understand the chemical hazards 

in the workplace, and how to protect workers from 

experiencing adverse effects. The procedures 

you establish regarding, for example, purchasing, 

storing, and handling of these chemicals will 

improve, and thereby reduce the risks posed to 

workers exposed to the chemical hazards involved. 

Furthermore, your workers’ comprehension will 

also be increased, and proper work practices will be 

more likely followed in your workplace.

If you are going to do the training yourself, you 

will have to understand the material and be 

prepared to motivate the workers to learn. This is 

not always an easy task, but the benefits are worth 

the effort. More information regarding appropriate 

training can be found in Appendix B of this guide, 

which provides steps to follow in setting up and 

conducting training.

In reviewing your hazard communication program 

with regard to information and training, the 

following items need to be considered:

1. Designation of person(s) responsible for 

conducting training;

2. Format of the program to be used 

(audiovisuals, classroom instruction, etc.);

3. Elements of the information and training 

program (should be consistent with the 

elements in paragraph (h) of the standard); and, 

4. Procedure to train new workers at the time 

of their initial assignment to work with a 

hazardous chemical, and to train workers 

when a new chemical hazard is introduced 

into the workplace.

The written program should provide enough 

details about the employer’s plans in this 

area to assess whether or not a good faith 

effort is being made to train workers. When 

assessing an employer’s compliance with hazard 

communication training requirements, OSHA 

CSHOs will talk to workers to determine if they 

have received training, if they know they are 

exposed to hazardous chemicals, and if they know 

where to obtain substance-specific information 

on labels and SDSs. It should be noted that if 

workers do not speak English, the employer must 

convey the hazard communication information 

in the language they understand—just like other 

job requirements and instructions are provided. 

OSHA has bilingual CSHOs, and they will be 

speaking to workers who speak another language 

to determine compliance.
Hazard Communication: Small Entity Compliance Guide for Employers That Use Hazardous Chemicals 27

The standard does not require employers to 

maintain records of employee training, but many 

employers choose to do so. This may help you 

monitor your own program to ensure that all 

workers are appropriately trained. Keeping records 

that document who was trained, when the training 

was conducted, and what was covered is also 

helpful to document compliance with OSHA’s 

training requirement in case of an inspection. The 

standard does not require retraining on a regular 

schedule, it simply requires retraining if there is 

a new chemical hazard introduced into the work 

area. If your initial training program includes all 

potential hazards covered by HazCom 2012, there 

is no retraining required. However, it is good 

business practice to repeat and reinforce what is 

learned in training to make sure that workers retain 

the hazard information. 

If you already have a hazard communication 

training program, you may simply have to update 

it to comply with HazCom 2012. In particular, by 

December 1, 2013, you will need to train your 

employees about the new label and SDS formats 

they will be seeing in their work areas. Additional 

hazard training is not required if you have already 

trained under the existing hazard communication 

requirements. However, after you receive all of 

the new labels and SDSs, and have updated your 

hazard communication program, you may find that 

there is a type of hazard on which employees have 

not yet received training. You will need to train 

employees on these new hazards at the time you 

become aware of the new hazard. If you become 

aware of new hazards after December 1, 2015, you 

will have until June 1, 2016 to ensure those hazards 

are included in the hazard communication program, 

the workplace labeling reflects these new hazards, 

and employees are trained on these new hazards.

An employer can provide employees information 

and training through whatever means are found 

appropriate. Although there will always have to be 

some training onsite (such as informing workers of 

the location and availability of the written program 

and SDSs), employee training may be satisfied in 

part by general training about the requirements 

of the HCS and about chemical hazards on the 

job which is provided by, for example, trade 

associations, unions, colleges, and professional 

schools. In addition, previous training, education 

and experience of a worker may relieve the 

employer of some of the burdens of informing and 

training that worker. Regardless of the method 

relied upon, however, the employer is always 

ultimately responsible for ensuring that workers 

are adequately trained. If the CSHO finds that the 

training is deficient, the employer will be cited for 

the deficiency regardless of who actually provided 

the training on behalf of the employer.
2 8 Occupational Safety and Health Administration

6. Evaluate and 

Reassess Your 

Program

•	 Review your hazard communication program periodically to 

make sure that it is still working and meeting its objectives.

•	 Revise your program as appropriate to address changed 

conditions in the workplace (e.g., new chemicals, new 

hazards, etc.).

Because your hazard communication program 

must remain up to date, it will be necessary to 

periodically evaluate and reassess your program.

The information in your written program must be 

accurate. The list of hazardous chemicals required 

to be maintained as part of the written program 

will serve as an inventory. As new chemicals are 

purchased, the list must be updated. Revisions to 

the inventory of chemicals should be made when 

you eliminate chemicals in the workplace, or when 

you bring in a new chemical. The inventory also 

can be used to ensure that you have SDSs for all 

chemicals in the workplace, and such revisions 

are key to ensuring that is achieved. In addition, 

designation of people to handle different parts of 

the program should also be current and accurate. 

Many companies have found it convenient to 

include on their purchase orders the name and 

address of the person designated in their company 

to receive SDSs to help maintain a complete set.

Program coordinators should routinely walk around 

the workplace to check that containers are labeled as 

required and that workers are following established 

work practices to protect themselves from chemical 

exposure. Proactive monitoring of the workplace is 

critical to ensuring compliance with the HCS.

As new SDSs are received, there should be a 

process in place to review them and determine 

whether any handling procedures need to change 

to protect against the hazards of these chemicals. 

Using information on the SDS effectively will make 

safer workplace conditions a standard business 

practice in your facility. 

This simple checklist will help to ensure that you 

are in compliance with the standard:

Obtained/accessed a copy of the standard. ____

Read and understood the requirements. ____

Assigned responsibility for tasks. ____

Prepared an inventory of chemicals. ____

Ensured that containers are labeled. ____

Obtained SDSs for each chemical. ____

Prepared written program. ____

Made SDSs available to workers. ____

Conducted training for workers. ____

Established procedures to maintain 

current program. ____

Established procedures to evaluate 

program effectiveness, including 

maintenance of SDSs. ____
Hazard Communication: Small Entity Compliance Guide for Employers That Use Hazardous Chemicals 2 9

III. CONCLUSION

OSHA believes that the Hazard Communication 

Standard is of critical importance to ensuring that 

hazardous chemicals are identified, and that proper 

measures are implemented in workplaces to 

achieve safe use and handling. By understanding 

the hazards of the chemicals, and using available 

information to pick the proper control measures 

to address these hazards, employers can achieve 

many benefits for themselves, as well as for their 

exposed workers. HazCom 2012 provides the 

framework for building a chemical safety and 

health management program in a workplace. 

Figure 6 illustrates the steps that have been 

discussed to ensure that a workplace hazard 

communication program is effective. 

Figure 6: An Effective Hazard Communication Program

Effecve Hazard 

Communicaon 

Program 

Read and Understand

the Standard; Assign

Responsibilies for

Tasks 

Prepare and 

Implement a Wrien 

Hazard

Communicaon 

Program with

Chemical List 

Ensure All Containers 

are Labeled 

Maintain Safety Data

Sheets for All 

Hazardous Chemicals 

and Make Accessible

to Employees

Inform and Train 

Employees About the 

HCS, Workplace

Hazards, and

Protecve Measures

Establish Procedures

to Update When 

Necessary; Evaluate 

Effecveness; Use 

Informaon to Select 

and Maintain Needed 

Protecve Measures
3 0 Occupational Safety and Health Administration

APPENDIX A: 

SAMPLE WRITTEN HAZARD 

COMMUNICATION PROGRAM

The following sample hazard communication 

program is based on the requirements of the 

Hazard Communication Standard (HazCom 2012), 

29 CFR 1910.1200. The intent of this sample is to 

provide an easy-to-use format that can be modified 

to address the specific situation in your workplace. 

You are free to use whatever format you choose to 

develop your program—there is no requirement to 

follow this example. However, if you use this or any 

other sample program, you must customize it to 

your specific workplace, otherwise you will not be 

in compliance with the HCS. 

HAZARD COMMUNICATION PROGRAM

1. Company Policy

To ensure that information about the dangers of all 

hazardous chemicals used by (Name of Company) 

is known by all affected workers, the following 

hazard communication program has been 

implemented. Under this program, workers will be 

informed of the requirements of the OSHA Hazard 

Communication Standard, the operations where 

exposure to hazardous chemicals may occur, and 

how workers can access this program, as well as 

labels and SDSs.

This program applies to any chemical which is 

known to be present in the workplace in such 

a manner that workers may be exposed under 

normal conditions of use or in a foreseeable 

emergency. All work areas that involve potential 

exposure to chemicals are part of the hazard 

communication program. Copies of the hazard 

communication program are available in the 

(location) for review by any interested worker.

(Name of responsible person and/or position) is the 

program coordinator, with overall responsibility for 

the program, including reviewing and updating this 

plan as necessary.

2. Container Labeling

(Name of responsible person and/or position) will 

verify that all containers received for use will be 

clearly labeled in accord with the requirements 

of HazCom 2012, including a product identifier, 

pictogram, hazard statement, signal word, and 

precautionary statements, as well as the supplier’s 

contact information (name and address).

The (name of responsible person and/or position) 

in each work area will ensure that all secondary 

containers are labeled with the original supplier’s 

label or with an alternative workplace label. For 

help with labeling, see (name of responsible 

person and/or position).

On the following individual stationary process 

containers, we are using (description of labeling 

system used) rather than a label to convey the 

required information:

(List containers here)

We are using an in-house labeling system 

(describe any in-house system which conveys 

required workplace label information).

The (name of responsible person and/or position) 

will review the company labeling procedures every 

(provide a time period) and will update labels as 

required.

3. Safety Data Sheets (SDSs)

The (name of responsible person and/or position) 

is responsible for establishing and monitoring the 

company SDS program. The procedure below will 

be followed when an SDS is not received at the 

time of initial shipment:

(Describe procedure to be followed here)

Copies of SDSs for all hazardous chemicals to 

which workers are exposed or are potentially 

exposed will be kept in (identify location). Workers 

can access SDSs by (insert procedure for access).

Note: If alternatives to paper copies of SDSs are 

used, describe the format used and how workers 

can access the SDSs.
Hazard Communication: Small Entity Compliance Guide for Employers That Use Hazardous Chemicals 31

SDSs will be readily available to all workers in each 

work area during each work shift. If an SDS is not 

available, contact (name of responsible person and/

or position).

When revised SDSs are received, the following 

procedures will be followed to replace old SDSs:

(Describe procedures)

The (name of responsible person and/or position) 

is responsible for reviewing the SDSs received for 

safety and health implications, and initiating any 

needed changes in workplace practices.

4. Employee Information and Training

(Name of responsible person and/or position) is 

responsible for employee information and training.

Every worker who will be potentially exposed to 

hazardous chemicals will receive initial training 

on the Hazard Communication standard and this 

program before starting work. 

The training program for new workers is as follows 

(describe how the training will be presented, and 

what it will include).

Prior to introducing a new chemical hazard into 

any work area, each worker in that work area will 

be given information and training as outlined 

above for the new chemical hazard. The training 

format will be as follows:

(Describe training format, such as audiovisuals, 

interactive computer programs, classroom 

instruction, etc.)

5. Hazards of Non-routine Tasks

Periodically, workers are required to perform 

non-routine tasks that are hazardous. Examples 

of non-routine tasks are: confined space entry, 

tank cleaning, and painting reactor vessels. Prior 

to starting work on such projects, each affected 

worker will be given information by (Name of 

responsible person and/or position) about the 

hazardous chemicals he or she may encounter 

during such activity. This information will include 

specific chemical hazards, protective and safety 

measures the worker should use, and steps 

the company is taking to reduce the hazards, 

including ventilation, respirators, the presence of 

another worker (buddy systems), and emergency 

procedures.

6. Informing Other Employers/Contractors

It is the responsibility of (Name of responsible 

person and/or position) to provide other employers 

and contractors with information about hazardous 

chemicals that their workers may be exposed 

to on this work site, and suggested precautions 

for workers. It is the responsibility of (Name of 

responsible person and/or position) to obtain 

information about hazardous chemicals used by 

other employers to which our workers may be 

exposed.

Other employers and contractors will be provided 

with SDSs for hazardous chemicals generated by 

this company’s operations in the following manner:

(Describe company policy here)

In addition to providing a copy of an SDS to other 

employers, other employers will be informed of 

necessary precautionary measures to protect 

workers exposed to operations performed by this 

company.

Also, other employers will be informed of the hazard 

labels used by the company. If alternative workplace 

labeling systems are used, the other employers will 

be provided with information to understand the 

labels used for hazardous chemicals to which their 

workers may have exposure.

7. List of Hazardous Chemicals

A list of all known hazardous chemicals in the 

workplace is attached to this program. This list 

includes the name of each chemical, and the 

work area(s) in which each of the chemicals is 

used. Further information on each chemical may 

be obtained from the SDSs, located in (identify 

location).

When new chemicals are received, this list is 

updated within (x) days of introduction into the 

workplace. To ensure that any new chemical 

is added in a timely manner, the following 

procedures shall be followed:
3 2 Occupational Safety and Health Administration

(Identify procedures to be followed)

The hazardous chemical inventory is compiled and 

maintained by (Name of responsible person and/

or position and telephone number).

8. Chemicals in Unlabeled Pipes

Work activities may be performed by workers in 

areas where chemicals are transferred through 

unlabeled pipes. Prior to starting work in these 

areas, the worker shall be informed by (Name 

of responsible person and/or position) about 

the identity and hazards of the chemicals in the 

pipe, as well as required precautionary measures 

required to be followed. 

9. Program Availability

A copy of this program will be made available, 

upon request, to workers, their designated 

representatives, and OSHA.
Hazard Communication: Small Entity Compliance Guide for Employers That Use Hazardous Chemicals 3 3

APPENDIX B: 

QUICK GUIDE TO HAZARD 

COMMUNICATION TRAINING

The Hazard Communication Standard (HCS) (29 

CFR 1910.1200) requires employers that have 

hazardous chemicals in their workplaces to 

implement a hazard communication program. 

The program includes information about labels on 

containers, safety data sheets (SDSs), and training 

for workers. Each employer must describe in a 

written program how it will meet the requirements 

of the HCS in each of these areas.

For employers that use chemicals, rather than 

produce them, labels and SDSs are received 

with the products they purchase. These written 

documents form the basis of the hazard 

communication program, providing information 

for both employers and workers about the hazards 

of the chemicals, as well as ways to protect people 

from experiencing adverse effects as a result of 

their use. Training is the last step to be undertaken 

to implement an effective hazard communication 

program. Through proper training, the employer 

has the opportunity to ensure that workers 

understand the hazards of the chemicals they work 

with, as well as what steps to take to ensure that 

they are protected from them. It also introduces 

them to labels and SDSs, explaining how to 

access these documents in their own workplace 

to obtain additional information. Training is 

therefore a critical part of the approach to hazard 

communication, tying together the three major 

components in an understandable form.

Before providing training, the employer should 

have a basic understanding of the requirements 

of the HCS, and have prepared its hazard 

communication program. This quick guide will 

focus on what is needed to set up a hazard 

communication training program. It is based on 

Training Requirements in OSHA Standards and 

Training Guidelines (OSHA 2254) developed by 

OSHA to assist employers to design any type of 

occupational safety and health training program, 

but relates the Guidelines specifically to hazard 

communication. It is a step-by-step approach. 

OSHA has also developed a series of QuickCardsTM 

on elements of the training that employers 

may find useful: www.osha.gov/dsg/hazcom/

ghsquickcards.html.

Training Step Factors to Consider

Determining 

if training is 

needed

Are workers potentially exposed to hazardous chemicals in your workplace? You can determine 

this by reviewing the labels received on containers of chemicals you use, as well as safety data 

sheets (SDSs). You must have a hazard communication program if you have workers who are 

potentially exposed to hazardous chemicals. Training workers is part of the required hazard 

communication program. Therefore, training is needed wherever workers are potentially 

exposed to hazardous chemicals in their workplaces.

Identifying 

training needs

Workers must be trained before they are initially assigned to work where they are potentially 

exposed to a hazardous chemical. Therefore, if you have never provided training before, you 

must train all workers who are potentially exposed. Once this initial training is completed, you 

must train any new workers who are hired and will be working with hazardous chemicals. You 

must also provide training whenever a new hazard is introduced, or when workers change 

jobs and therefore face potential exposures. While training is not required to be repeated on 

a regular basis, you may want to consider doing that to be sure that workers remember what 

they have learned. It is also a good opportunity for you to review your hazard communication 

program, and make sure that it is still working effectively.
3 4 Occupational Safety and Health Administration

Training Step Factors to Consider

Identifying 

goals and 

objectives

Compliance with the requirements of the Hazard Communication Standard is a primary goal. 

Compliance will promote a safer workplace by ensuring that the potential hazards of chemicals 

are known both to you and to your workers. In addition, the measures to follow to prevent 

adverse health or physical effects resulting from chemical exposures should be familiar to 

everyone in the workplace. Preparing for the training gives you an opportunity to review the 

hazards of the chemicals you have in the workplace, and to consider substituting less hazardous 

chemicals where appropriate. It also allows you to review the protective measures you have 

in place to ensure that they are working, and to consider other types of protection as well. 

Implementation of a hazard communication program should be useful both to employers 

that have hazardous chemicals as part of their workplace processes, and to workers who are 

exposed to those chemicals. Training ties together all of the aspects of the workplace hazard 

communication program to relate it to the actual workplace conditions. Thus both employers 

and workers should be more familiar with the hazards present, know what steps must be taken 

to control those hazards, and be assured that the workplace is safer. They should also know how 

to obtain more information when needed from the container labels and the SDSs.

You may want to consider if you have any additional learning objectives you would like to 

accomplish through this training program. For example, you may also have compliance 

obligations for related standards that could be combined into this program and accomplished 

in one training session (such as training required under the Respiratory Protection standard). 

Also, it may be an opportunity to review safe work practices and ways to perform jobs in a more 

efficient manner, and tie this into avoiding chemical hazards.

Identifying 

learning 

activities

The Hazard Communication Standard specifies what information must be provided to workers:

•	 The requirements of the Hazard Communication Standard;

•	 Any operations in their work area where hazardous chemicals are present; and

•	 The location and availability of the written hazard communication program, including the 

required list(s) of hazardous chemicals, and SDSs required by the standard.

In addition to providing this information to workers, they must be trained on the following:

•	 Methods and observations that may be used to detect the presence or release of a 

hazardous chemical in the work area (such as monitoring conducted by the employer, 

continuous monitoring devices, visual appearance or odor of hazardous chemicals when 

being released, etc.);

•	 The physical and health hazards of the chemicals in the work area;

•	 The measures workers can take to protect themselves from these hazards, including specific 

procedures the employer has implemented to protect workers from exposure to hazardous 

chemicals, such as appropriate work practices, emergency procedures, and personal 

protective equipment to be used; and

•	 The details of the hazard communication program developed by the employer, including an 

explanation of the labeling system and the SDS, and how workers can obtain and use the 

appropriate information.

The way in which this information is conveyed is left up to the trainer to determine. You can 

use any type of media available to you (such as slides, videos, computer interactive programs). 

Combinations of media are often an effective way to keep the workers’ attention. In addition, 

active participation is important, so you may want to include learning activities that allow the 

workers to participate and have hands-on experiences. Relating the information to their specific 

workplace conditions helps to ensure that you meet the requirements of the standard, as well as 

improving learning and making the training more interesting.
Hazard Communication: Small Entity Compliance Guide for Employers That Use Hazardous Chemicals 3 5

Training Step Factors to Consider

Conducting the 

training

Preparation: In order to train workers under the Hazard Communication Standard, the trainer 

must be familiar with: 

•	 the requirements of the standard that apply to the workplace; 

•	 the hazardous chemicals in the workplace to which workers are potentially exposed, as well 

as the types of hazards they pose; 

•	 the hazard communication program implemented in the workplace; and 

•	 the protective measures being employed in the workplace to prevent adverse effects from 

occurring.

In addition to being thoroughly familiar with the material to be covered in the training, the 

trainer must be aware of the facilities available for the training, including the physical location, 

the type of equipment (e.g., a PowerPoint projector, computer), and plan the training session 

accordingly based on the conditions. 

Presenting the training: The purpose of the training is to convey information that is important 

to the student, and will achieve a safer workplace. Care should be taken to ensure that the 

facilities are conducive to a successful training session, and that the presentation is done in 

a way that motivates learning and a positive outcome. Worker participation helps to ensure 

that the learning objectives are accomplished. This can be done through hands-on examples, 

discussions, and other active means of conveying the required information.

Evaluating 

program 

effectiveness

Consideration should be given to including some sort of evaluation tool in the training to obtain 

feedback from the workers on the presentation, what formats might work better, and what they 

learned. This could be in the form of a sheet to be filled out by workers after the training. In 

evaluating the effectiveness of the program, you should observe how the training has changed 

worker behavior. For example, if workers have better compliance with use of protective measures 

(such as wearing gloves when appropriate), this could factor into the evaluation of the program.

Improving the 

training

The trainers should use their own impressions as well as feedback from the students to improve 

the training before it is presented again. If workers are not interested in the training as it is 

conducted, do not appear motivated, and do not exhibit an increased knowledge of hazards and 

the use of protective practices, it may be necessary to review and revise the training to achieve 

a better outcome.

Following these seven steps should enable you 

to design and implement an effective hazard 

communication training program. A safer workplace 

benefits the employer as well as the worker, and 

their shared interest in this goal should help to 

achieve effective hazard communication training.
3 6 Occupational Safety and Health Administration

WORKERS’ RIGHTS

Under OSHA law, workers are entitled to working 

conditions that do not pose a risk of serious harm. 

To help assure a safe and healthful workplace, the 

law provides workers with the right to:

■ File a confidential complaint with OSHA to have 

their workplace inspected.

■ Receive information and training about 

hazards, methods to prevent harm, and the 

OSHA standards that apply to their workplace. 

The training must be done in a language and 

vocabulary workers can understand.

■ Receive copies of records of work-related injuries 

and illnesses that occur in their workplace.

■ Receive copies of the results from tests and 

monitoring done to find and measure hazards 

in their workplace.

■ Receive copies of their workplace medical 

records.

■ Participate in an OSHA inspection and speak in 

private with the inspector.

■ File a complaint with OSHA if they have been 

retaliated against by their employer as the 

result of requesting an inspection or using any 

of their other rights under the OSH Act.

■ File a complaint if punished or retaliated 

against for acting as a “whistleblower” under 

the 21 additional federal laws for which OSHA 

has jurisdiction.

For more information, visit OSHA’s Workers’ Rights 

page at www.osha.gov/workers.html. 

OSHA ASSISTANCE, SERVICES AND PROGRAMS

OSHA offers free compliance assistance to 

employers and workers. Several OSHA programs 

and services can help employers identify and 

correct job hazards, as well as improve their injury 

and illness prevention program.

Establishing an Injury and Illness 

Prevention Program

The key to a safe and healthful work environment 

is a comprehensive injury and illness prevention 

program.

Injury and illness prevention programs are 

systems that can substantially reduce the number 

and severity of workplace injuries and illnesses, 

while reducing costs to employers. Thousands 

of employers across the United States already 

manage safety using illness and injury prevention 

programs, and OSHA believes that all employers 

can and should do the same. Thirty-four states 

have requirements or voluntary guidelines for 

workplace injury and illness prevention programs. 

Most successful injury and illness prevention 

programs are based on a common set of key 

elements. These include management leadership, 

worker participation, hazard identification, hazard 

prevention and control, education and training, 

and program evaluation and improvement. Visit 

OSHA’s illness and injury prevention program web 

page at www.osha.gov/dsg/topics/safetyhealth for 

more information.

Compliance Assistance Specialists

OSHA has compliance assistance specialists 

throughout the nation located in most OSHA 

offices. Compliance assistance specialists can 

provide information to employers and workers 

about OSHA standards, short educational 

programs on specific hazards or OSHA rights and 

responsibilities, and information on additional 

compliance assistance resources. For more details, 

visit www.osha.gov/dcsp/compliance_assistance/

cas.html or call 1-800-321-OSHA [6742] to contact 

your local OSHA office.
Hazard Communication: Small Entity Compliance Guide for Employers That Use Hazardous Chemicals 37

Free On-site Safety and Health 

Consultation Services for Small Business

OSHA’s On-site Consultation Program offers free 

and confidential advice to small and medium-sized 

businesses in all states across the country, with 

priority given to high-hazard worksites. Each year, 

responding to requests from small employers 

looking to create or improve their safety and 

health management programs, OSHA’s On-site 

Consultation Program conducts over 29,000 visits 

to small business worksites covering over 1.5 

million workers across the nation.

On-site consultation services are separate from 

enforcement and do not result in penalties or 

citations. Consultants from state agencies or 

universities work with employers to identify 

workplace hazards, provide advice on compliance 

with OSHA standards, and assist in establishing 

safety and health management programs.

For more information, to find the local On-site 

Consultation office in your state, or to request a 

brochure on Consultation Services, visit www.osha.

gov/consultation, or call 1-800-321-OSHA [6742].

Under the consultation program, certain exemplary 

employers may request participation in OSHA’s 

Safety and Health Achievement Recognition 

Program (SHARP). Eligibility for participation 

includes, but is not limited to, receiving a fullservice, comprehensive consultation visit, 

correcting all identified hazards and developing an 

effective safety and health management program. 

Worksites that receive SHARP recognition are 

exempt from programmed inspections during the 

period that the SHARP certification is valid.

Cooperative Programs

OSHA offers cooperative programs under which 

businesses, labor groups and other organizations 

can work cooperatively with OSHA. To find out 

more about any of the following programs, visit 

www.osha.gov/dcsp/compliance_assistance/

index_programs.html.

Strategic Partnerships and Alliances

The OSHA Strategic Partnerships (OSP) 

provides the opportunity for OSHA to partner 

with employers, workers, professional or 

trade associations, labor organizations, and/or 

other interested stakeholders. OSHA Strategic 

Partnerships are formalized through unique 

agreements designed to encourage, assist, and 

recognize partner efforts to eliminate serious 

hazards and achieve model workplace safety and 

health practices. Through the Alliance Program, 

OSHA works with groups committed to worker 

safety and health to prevent workplace fatalities, 

injuries and illnesses by developing compliance 

assistance tools and resources to share with 

workers and employers, and educate workers and 

employers about their rights and responsibilities.

Voluntary Protection Programs (VPP)

The VPP recognize employers and workers 

in private industry and federal agencies who 

have implemented effective safety and health 

management programs and maintain injury and 

illness rates below the national average for their 

respective industries. In VPP, management, labor, 

and OSHA work cooperatively and proactively to 

prevent fatalities, injuries, and illnesses through a 

system focused on: hazard prevention and control, 

worksite analysis, training, and management 

commitment and worker involvement.

Occupational Safety and Health Training

The OSHA Training Institute in Arlington Heights, 

Illinois, provides basic and advanced training 

and education in safety and health for federal 

and state compliance officers, state consultants, 

other federal agency personnel and private sector 

employers, workers, and their representatives. 

In addition, 27 OSHA Training Institute Education 

Centers at 42 locations throughout the United 

States deliver courses on OSHA standards and 

occupational safety and health issues to thousands 

of students a year.

For more information on training, contact the 

OSHA Directorate of Training and Education, 2020 

Arlington Heights Road, Arlington Heights, IL 

60005; call 1-847-297-4810; or visit www.osha.gov.
3 8 Occupational Safety and Health Administration

OSHA Educational Materials

OSHA has many types of educational materials in 

English, Spanish, Vietnamese and other languages 

available in print or online. These include:

■ Brochures/booklets that cover a wide variety of 

job hazards and other topics;

■ Fact Sheets, which contain basic background 

information on safety and health hazards;

■ Guidance documents that provide detailed 

examinations of specific safety and health issues;

■ Online Safety and Health Topics pages;

■ Posters;

■ Small, laminated QuickCardsTM that provide 

brief safety and health information; and

■ QuickTakes, OSHA’s free, twice-monthly online 

newsletter with the latest news about OSHA 

initiatives and products to assist employers 

and workers in finding and preventing 

workplace hazards. To sign up for QuickTakes

visit OSHA’s web site at www.osha.gov and 

click on QuickTakes at the top of the page.

To view materials available online or for a listing 

of free publications, visit OSHA’s web site at www.

osha.gov. You can also call 1-800-321-OSHA [6742] 

to order publications.

OSHA’s web site also has a variety of eTools. 

These include utilities such as expert advisors, 

electronic compliance assistance, videos and other 

information for employers and workers. To learn 

more about OSHA’s safety and health tools online, 

visit www.osha.gov.

NIOSH HEALTH HAZARD 

EVALUATION PROGRAM

Getting Help with Health Hazards

The National Institute for Occupational Safety and 

Health (NIOSH) is a federal agency that conducts 

scientific and medical research on workers’ safety 

and health. At no cost to employers or workers, 

NIOSH can help identify health hazards and 

recommend ways to reduce or eliminate those 

hazards in the workplace through its Health Hazard 

Evaluation (HHE) Program.

Workers, union representatives and employers can 

request a NIOSH HHE. An HHE is often requested 

when there is a higher than expected rate of a 

disease or injury in a group of workers. These 

situations may be the result of an unknown cause, 

a new hazard, or a mixture of sources. To request 

a NIOSH Health Hazard Evaluation go to www.

cdc.gov/niosh/hhe/request.html. To find out more 

about the Health Hazard Evaluation Program:

■ Call (513) 841-4382, or to talk to a staff member 

in Spanish, call (513) 841-4439; or

■ Send an email to HHERequestHelp@cdc.gov.
Hazard Communication: Small Entity Compliance Guide for Employers That Use Hazardous Chemicals 3 9

OSHA REGIONAL OFFICES

Region I

Boston Regional Office

(CT*, ME, MA, NH, RI, VT*) 

JFK Federal Building, Room E340

Boston, MA 02203

(617) 565-9860 (617) 565-9827 Fax 

Region II

New York Regional Office

(NJ*, NY*, PR*, VI*)

201 Varick Street, Room 670

New York, NY 10014

(212) 337-2378 (212) 337-2371 Fax

Region III

Philadelphia Regional Office

(DE, DC, MD*, PA, VA*, WV)

The Curtis Center

170 S. Independence Mall West

Suite 740 West

Philadelphia, PA 19106-3309

(215) 861-4900 (215) 861-4904 Fax

Region IV 

Atlanta Regional Office

(AL, FL, GA, KY*, MS, NC*, SC*, TN*)

61 Forsyth Street, SW, Room 6T50

Atlanta, GA 30303

(678) 237-0400 (678) 237-0447 Fax

 

Region V

Chicago Regional Office

(IL*, IN*, MI*, MN*, OH, WI)

230 South Dearborn Street 

Room 3244

Chicago, IL 60604

(312) 353-2220 (312) 353-7774 Fax

Region VI

Dallas Regional Office

(AR, LA, NM*, OK, TX)

525 Griffin Street, Room 602

Dallas, TX 75202

(972) 850-4145 (972) 850-4149 Fax

(972) 850-4150 FSO Fax

Region VII

Kansas City Regional Office

(IA*, KS, MO, NE)

Two Pershing Square Building

2300 Main Street, Suite 1010

Kansas City, MO 64108-2416

(816) 283-8745 (816) 283-0547 Fax

Region VIII

Denver Regional Office

(CO, MT, ND, SD, UT*, WY*)

Cesar Chavez Memorial Building

1244 Speer Boulevard, Suite 551

Denver, CO 80204

(720) 264-6550 (720) 264-6585 Fax

Region IX 

San Francisco Regional Office

(AZ*, CA*, HI*, NV*, and American Samoa, 

Guam and the Northern Mariana Islands)

90 7th Street, Suite 18100

San Francisco, CA 94103

(415) 625-2547 (415) 625-2534 Fax

Region X

Seattle Regional Office

(AK*, ID, OR*, WA*)

300 Fifth Avenue, Suite 1280

Seattle, WA 98104

(206) 757-6700 (206) 757-6705 Fax

* These states and territories operate their own 

OSHA-approved job safety and health plans and 

cover state and local government employees as 

well as private sector employees. The Connecticut, 

Illinois, New Jersey, New York and Virgin Islands 

programs cover public employees only. (Private 

sector workers in these states are covered by 

Federal OSHA). States with approved programs 

must have standards that are identical to, or at 

least as effective as, the Federal OSHA standards.

Note: To get contact information for OSHA area 

offices, OSHA-approved state plans and OSHA 

consultation projects, please visit us online at 

www.osha.gov or call us at 1-800-321-OSHA (6742).
4 0 Occupational Safety and Health Administration

HOW TO CONTACT OSHA

For questions or to get information or advice, 

to report an emergency, report a fatality or 

catastrophe, order publications, sign up for 

OSHA’s e-newsletter QuickTakes, or to file a 

confidential complaint, contact your nearest 

OSHA office, visit www.osha.gov or call OSHA 

at 1-800-321-OSHA (6742), TTY 1-877-889-5627.

For assistance, contact us.

We are OSHA. We can help. 

42 Occupational Safety and Health Administration

The hazardous chemical inventory is compiled and maintained by (Name of responsible person and/or 

position and telephone number).

8. Chemicals in Unlabeled Pipes

Work activities may be performed by workers in areas where chemicals are transferred through 

unlabeled pipes. Prior to starting work in these areas, the worker shall be informed by (Name of 

responsible person and/or position) about the identity and hazards of the chemicals in the pipe, as well 

as required precautionary measures required to be followed. 

9. Program Availability

A copy of this program will be made available, upon request, to workers, their designated 

representatives, and OSHA.

For more information:

Occupational

Safety and Health

Administration

www.osha.gov (800) 321-OSHA (6742)

U.S. Department of Labor