Hazard Communication: Your Guide to the OSHA Safety Standard

Hazard Communication is a frequent offender on OSHA’s top 10 most frequently cited standards list—despite it being one of the administration’s most important safety standards. The Occupational Safety and Health Administration (OSHA) puts forth hazard communication guidelines for compliance to give workers the right to know and understand risks and hazards in their workplace.

Hazard Communication (hazcom) is a vital safety standard for organizations, industry-wide—and one that operations managers need to consider. The standard applies to almost all operations, and a recent analysis from Traceone found 5.6 hazard communication violations per 100,000 workers. Staying ahead of hazcom compliance is crucial.

Workplace Hazards to Communicate

Hazardous chemicals or other materials that threaten human, environmental, and community well-being are commonplace at worksites. A chemical is considered “hazardous” if it is classified as a physical or health threat, including simple asphyxiants, combustible dusts, and pyrophoric gases, as well as hazards not otherwise classified.

What's the difference between physical and health hazards?

Physical Hazards

Physical chemical hazards include risks to employees with or without direct contact:

• Explosivity
• Flammability
• Oxidation
• Reactivity
• Corrosive
• Pressurized
• And more

Health Hazards

Exposure to health hazards cause acute or chronic injury, illness, or death:

• Toxicity – including reproductive hazards
• Corrosion
• Irritation
• Carcinogenicity
• Mutagenicity
• And more

Why are chemicals so hazardous?

Chemicals and other hazardous materials can cause irritation and carcinogenicity, among other consequences, and there are different exposure levels that are “acceptable” depending on the material. In fact, there are even different categories of HAZMAT suits that offer varying levels of protection to the workers who wear them—and the choice of personal protective equipment (PPE) level comes down to the substances the worker interacts with.

Hazardous materials are liable to spill or leak, which can mean direct exposure to human skin or lungs, or worker slips in puddles or wet spots. They may also be explosive, which can result in shrapnel and other equally serious consequences—such as death or damage to a facility’s structure and equipment. This means that these hazardous chemicals can be present in the air, on the ground, or actually within the materials workers use daily, either combined with other substances or in pure form—which makes them that much more dangerous.

Any worksite that stores, handles, manages, uses, or otherwise has onsite chemicals needs to effectively communicate physical and health risks to employees. Other regulatory hazard communication requirements may also require communication of other hazards as well—biological, ergonomics, noise, heat, etc.—but OSHA hazcom compliance is strictly about hazardous chemicals.

The OSHA Hazard Communication Standard

The risks posed by hazardous workplace substances led to OSHA developing the Hazard Communication Standard (HCS) (standard 1910.1200). This standard outlines a worker's right to know and understand all chemical safety hazards that exist in their workplace.

As part of this standard, chemical identity and hazard information must be available and understandable to all workers. To make the system coherent in terms of hazard identification, OSHA synchronized the HCS with the Globally Harmonized System of Classification and Labelling (GHS) in the 2024 HCS final rule.

A hazard communication plan is required for organizations with these hazardous chemicals and materials onsite, and must include a variety of separate items:  

Hazard Classification (standard 1910.1200(d)(1)):

From OSHA: “Chemical manufacturers and importers shall evaluate chemicals produced in their workplaces or imported by them to classify the chemicals ... . For each chemical, the chemical manufacturer or importer shall determine the hazard classes and, where appropriate, the category of each class that apply to the chemical being classified. Employers are not required to classify chemicals unless they choose not to rely on the classification performed by the chemical manufacturer or importer … .”

In practice, this means that all relevant material hazard data must be identified to categorize that chemical within a hazard class. Informed by hazard classification by manufacturers and importers, hazard communications should list health and physical risks.

Labels and Safety Data Sheets (SDSs) (standard 1910.1200(b)(1)):

According to OSHA, “This section requires … all employers to provide information to their employees about the hazardous chemicals to which they are exposed, by means of a hazard communication program, labels and other forms of warning, safety data sheets, and information and training.”

Workplace Hazard Communication Methods

Practically, this means that incoming hazardous materials should always have a label outlining the relevant hazards, and this label should never be removed or defaced. All outgoing hazardous materials should be properly and legibly labeled as well. When new hazard information becomes available, labels must be updated within six months. Recently, OSHA updated label requirements within the HCS—labels must include a precautionary statement, pictograms, a harmonized signal word, and a hazard statement for each class and category.

For every hazardous chemical a facility produces or exports, a 16-section SDS is also required. These should be distributed downstream, from employers to employees. These SDSs should be current and readily accessible to workers at all times, and managers must ensure that these SDSs are included in all imports and exports from their facility. These should be kept in English, although it is encouraged that SDSs are available in other appropriate languages as well.

Hazard Communication Training (standard 1910.1200(g)(11)):

OSHA states: “Employers shall provide 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 to their work area.”

Employers need to train workers in the safe handling, use, and storage of any hazardous materials in their work area and broader facility. Employees must also be trained on label elements and SDSs, to ensure they understand and can recognize the hazards of the materials they are exposed to at work.

Written Hazard Communication Program

As part of 29 CFR 1910.1200, OSHA requires organizations to provide a written statement about how they plan to meet all aspects of the hazard communication standard. A written hazard communication plan must include information on how the organization plans to handle:

• Hazard classification
• Hazard communication methods like labelling and SDS use
• Hazard communication training
• And more

Risk of Hazard Communication Failures

Non-compliance with this standard potentially exposes facilities to fines of up to $16,550 per violation and penalties of over ten times as much per citation if the violation is willful or repeated. On top of this, lacking hazard communication can result in avoidable accidents that can reduce safety culture, cause lost work time, and even negatively impact brand reputation. This underscores the prevalence of Hazard Communication standard violations—and the need to learn how to avoid being cited.

Any unwanted and often unpredictable chemical event can pose a threat to human safety. They can also shut down operations, causing lost money as well as something no organization can ever recover—time.

Hazard Communication Best Practices

The HCS sections outlined above, among others, are often overlooked by managers—leaving their organizations non-compliant. Luckily, facility managers can achieve compliance and so avoid HCS-related OSHA citations by observing the following practices:

• Regularly review chemical inventory: This will help ensure that employees know exactly what hazardous materials exist within the facility. Knowing exactly what is stored can help make sure that all of these chemicals have appropriate labels and easily-accessible SDSs. Managers should also review the guidance for these hazardous materials—and when doing so, as appropriate, update SDSs with new information.
• Understand the hazard classification criteria: Knowing hazard classification criteria increases awareness of the exact risks of working with the hazardous materials they classify. In turn, this will help promote better understanding of mitigation strategies during exposure—including during PPE selection or by keeping on-site material quantities under pre-set safety thresholds.
• Prioritize training: In the EHS industry overall, proper hazard communication training is paramount. Efficient, thorough, and well-designed EHS training is a proven way to make sure that employees are getting the best possible information. Customizable, engaging, and easily trackable trainings will help employees succeed.
• Standardize documentation for audit readiness: Consistent documentation across sites ensures defensibility during inspections and reduces risk exposure.
• Regularly check for HCS updates: OSHA often modifies HCS guidance. Regular checks for updates and as-needed changes to operational safety plans will help promote compliance.

Following these steps will help avoid OSHA HCS violations and fines—and contribute to overall compliance and worker safety.

Interested in learning more about improving workplace safety through hazard communication? Talk to one of our EHS consultants today.

Hazard Communication FAQ