Do I Need a Hazard Communication Program?
The Short Answer
If any employee in your workplace may be exposed to hazardous chemicals under normal conditions or in a foreseeable emergency, you need a written Hazard Communication Program. This is required under 29 CFR 1910.1200(e) (federal) and T8 CCR 5194 (California).
What Counts as a Hazardous Chemical
The definition is broad. Concrete, paint, solvents, adhesives, fuels, welding fumes, cleaning products, epoxies, and compressed gases all qualify. If a product has a Safety Data Sheet (SDS), it is a hazardous chemical under the standard. Most construction trades and general industry operations have at least some chemical exposure.
What the Program Must Include
A written HazCom program must address: (1) A list of hazardous chemicals in the workplace (chemical inventory). (2) Safety Data Sheet management — how SDSs are obtained, maintained, and made accessible to employees. (3) Container labeling — how containers are labeled with product identity, hazard warnings, and GHS pictograms. (4) Employee training — initial and refresher training on chemical hazards, SDS interpretation, label reading, and protective measures.
The GHS Update
OSHA updated the HazCom standard in 2012 and again in 2024 to align with the Globally Harmonized System (GHS) of chemical classification. The 2024 update (effective 2026 for most employers) adds requirements for small container labeling and harmonizes classification criteria. Your program must reference the current GHS-aligned standard.
Multi-Employer Worksites
On construction sites with multiple employers, the general contractor must ensure HazCom information is shared between employers. Each employer must maintain their own program, but chemical hazard information must be accessible to all workers on site.
Penalties
HazCom is consistently among OSHA's top 10 most cited standards. Average penalty for a serious violation: $16,550. Cal/OSHA can issue higher penalties.
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