Steps to an Effective Hazard 

Communication Program for Employers 

That Use Hazardous Chemicals

Employers that have hazardous chemicals in their workplaces are required by 

OSHA’s Hazard Communication Standard (HCS), 29 CFR 1910.1200, to implement a 

hazard communication program. The program must include labels on containers of 

hazardous chemicals, safety data sheets (SDSs) for hazardous chemicals, and training 

for workers. Each employer must also describe in a written program how it will meet 

the requirements of the HCS in each of these areas.

Employers can implement an effective hazard 

communication program by following these 

six steps:

Step 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 may obtain a copy of the Hazard 

Communication Standard on OSHA’s hazard 

communication webpage at www.osha.gov/

hazcom. The provisions of the standard that 

apply to employers using chemicals in their 

workplaces are found primarily in paragraphs 

(e) written hazard communication program; (f) 

labels and other forms of warning; (g) safety 

data sheets; and (h) employee information and 

training. It is important that you become familiar 

with these provisions to determine what is 

needed for compliance in your workplace.

In order to ensure that you have an effective 

hazard communication program, and address all 

of the necessary components, responsibility for 

implementation of hazard communication should 

be assigned to someone to coordinate. The person 

designated for overall program coordination 

should then identify staff to be responsible for 

particular activities, such as training.

Step 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) of the standard requires employers 

to prepare and implement a written hazard 

communication program. This requirement is to 

help ensure that compliance with the standard is 

done in a systematic way, and that all elements 

are coordinated. The written program must 

indicate how you will address the requirements 

of paragraphs (f) labels and other forms of 

warning; (g) safety data sheets; and (h) employee 

information and training, in your workplace.

The written program also requires employers 

to maintain a list of the hazardous chemicals 

known to be present in the workplace. Using the 

product identifier (e.g., product name, common 

name, or chemical name) to prepare the list will 

make it easier for you to track the status of SDSs 

and labels of a particular hazardous chemical. 

Remember, the product identifier must be the 

same name that appears on the label and SDS of 

the hazardous chemical. 

Step 3. Ensure Containers are Labeled

• Keep labels on shipped containers.

• Label workplace containers where required.

FactSheet
Chemical manufacturers and importers are 

required to provide labels on shipped containers 

with the following information: product identifier, 

signal word, pictograms, hazard statements, 

precautionary statements, and the name, 

address and phone number of the responsible 

party. Therefore, when an employer receives a 

hazardous chemical from a supplier, all of this 

information will be located together on the label; 

however, additional information may also appear. 

As the employer, you are required to ensure 

that containers in the workplace are labeled. 

You may use the same label from the supplier 

or you may label workplace containers with 

alternatives, such as third party systems (e.g., 

National Fire Protection Association (NFPA) 

or Hazardous Materials Identification System 

(HMIS)) in addition to the other required 

information. Any container of hazardous 

chemicals in the workplace must at a minimum 

include the product identifier and general 

information concerning the hazards of the 

chemical. Whatever method you choose, your 

workers need to have access to the complete 

hazard information. 

Step 4. Maintain Safety Data 

Sheets (SDSs)

• Maintain safety data sheets for each 

hazardous chemical in the workplace.

• Ensure that safety data sheets are readily 

accessible to employees.

Safety data sheets are the source of detailed 

information on a particular hazardous chemical. 

Employers must maintain copies of SDSs 

for all hazardous chemicals present in their 

workplaces. If you do not receive an SDS 

from your supplier automatically, you must 

request one. You also 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., outside of the safety 

office, in the pick-up truck on a construction 

site). Others, particularly in workplaces with 

large numbers of chemicals, provide access 

electronically. However, if SDSs are supplied 

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. In addition, the employer must ensure 

that workers are trained on how to use the 

system to access SDSs and are able to obtain 

hard copies of the SDSs. In the event of a 

medical emergency, hard copy SDSs must be 

immediately available to medical personnel. 

Step 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.

Paragraph (h) of the HCS requires that employers 

train employees on the hazardous chemicals in 

their work area before their initial assignment 

and when new hazards are introduced into the 

work area, and this training must be conducted 

in a manner and language that employees can 

understand. Workers must understand they are 

exposed to hazardous chemicals. They must 

know that labels and safety data sheets can 

provide them with information on the hazards of 

a chemical, and these items should be consulted 

when needed. In addition, workers must have 

a general understanding of what information is 

provided on labels and SDSs, and how to access 

them. They must also be aware of the protective 

measures available in their workplace, how to 

use or implement these measures, and whom 

they should contact if an issue arises. 

Step 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.).
DSG FS-3696 03/2014

This is one in a series of informational fact sheets highlighting OSHA programs, policies or standards. 

It does not impose any new compliance requirements. For a comprehensive list of compliance 

requirements of OSHA standards or regulations, refer to Title 29 of the Code of Federal Regulations. 

This information will be made available to sensory-impaired individuals upon request. The voice 

phone is (202) 693-1999; teletypewriter (TTY) number: (877) 889-5627.

Although the HCS does not require you 

to evaluate and reassess your hazard 

communication program, it must remain current 

and relevant for you and your employees. 

The best way to achieve that is to review your 

hazard communication program periodically to 

make sure that it is still working and meeting 

its objectives and to revise it as appropriate to 

address changed conditions in the workplace 

(e.g., new chemicals, new hazards, etc.).

Additional Information 

See Hazard Communication: Small Entity 

Compliance Guide for Employers That 

Use Hazardous Chemicals for more 

detailed information on how to implement 

an effective hazard communication program. 

Additional information on the Hazard 

Communication Standard can be found on 

OSHA’s Hazard Communication webpage at 

www.osha.gov/hazcom.