A filled-in template does not keep your chemical list current, replace a smeared label on a spray bottle, or get a safety data sheet to a night-shift worker. Programs fall behind when that upkeep slips. If employees may encounter hazardous chemicals during normal work or a foreseeable emergency, you generally need a Hazard Communication program. Company size creates no general exemption from OSHA’s Hazard Communication Standard.
Quick Answer
Set up HazCom by naming a responsible person, listing hazardous chemicals, keeping an SDS for each, checking shipped and workplace labels, documenting required procedures, and training affected employees. The rule is 29 CFR 1910.1200. OSHA’s free sample program is a framework you must adapt. A completed template is not evidence of compliance.
Table of Contents
- Does HazCom Apply to Your Business?
- How to Set Up Your HazCom Program
- What Belongs on a GHS Shipped-Container Label?
- Practical HazCom Checklist
- How Helios Comply Helps
- Frequently Asked Questions
Does HazCom Apply to Your Business?
Exposure, not headcount, is the test. The standard covers workplaces where employees may be exposed to hazardous chemicals in normal operations or foreseeable emergencies.
Not every chemical on the property creates the same duties. The standard has scope limits and exemptions for certain products and uses. Staff who meet chemicals only in isolated situations are not treated like employees who regularly handle hazardous cleaners, coatings, fuels, or process chemicals. Get qualified advice when the answer is unclear. Helios Comply’s plain-language guide to 29 CFR 1910.1200 helps frame that review.
Related guidance: full HazCom requirements.
Related guidance: complete small business SDS compliance guide.
How to Set Up Your HazCom Program
Related guidance: keep your SDS system current.
Related guidance: employee HazCom training.
1. Put one person in charge
Choose a manager or safety lead to own the chemical list, SDS library, labels, written program, and training records. That person needs authority to stop unlabeled chemicals, chase missing SDSs, and revise procedures as hazards change.
2. Build your hazardous chemical list
Walk each work area, storage room, service vehicle, and maintenance space and record every hazardous chemical employees may encounter. Each product identifier should match the label and SDS. Purchase records are a starting point only: check older stock and products taken to jobsites.
Separate spreadsheets can drift across sites. Helios Comply keeps a central chemical and SDS library with location-scoped records, so each site’s list stays distinct.
Related guidance: QR-code SDS access built for small business.
Related guidance: organizing your SDS documents.
Related guidance: what ‘readily accessible’ really means.
3. Gather and organize safety data sheets
Obtain an SDS for every listed chemical and resolve missing documents and mismatches. Under paragraph (g)(8), SDSs must be readily accessible to employees in their work areas during each work shift. A locked office night-shift employees cannot enter falls short.
Paper, electronic access, or both can work if employees have ready access. Electronic access is permitted when it creates no barriers to immediate access. Test it under real conditions and plan for power or connectivity failures. This SDS binder guide covers paper setup.
Collecting the sheets can take time. Helios Comply digitizes uploads with AI assistance and pulls sheets from product identifiers, barcodes, or a container photo. Employees reach the library by QR code on mobile or offline.
Related guidance: HazCom inspection checklist.
4. Inspect shipped and workplace labels
Never remove or deface a label on an incoming container unless it is immediately marked with the required information. Quarantine unreadable containers until fixed.
For workplace containers, paragraph (f)(6) permits either the five hazard-related elements from shipped labels, without supplier contact information, or a product identifier plus words, pictures, or symbols giving at least general hazard information. Under the second option, employees need immediate access to the specific physical and health hazard information.
Transferring a chemical does not remove the labeling duty. The portable-container exemption in paragraph (f)(8) is narrow: it covers containers intended only for the immediate use of the employee who performs the transfer. As a conservative rule, label it if anyone else may use it, if it will be left behind, or if it stays in use next shift.
Hand-lettered secondary labels add another manual step. Helios Comply generates GHS secondary-container labels from the chemical record, so the bottle in the janitor’s closet matches the SDS.
5. Write the program for the workplace you have
Paragraph (e) requires a written program describing how you will meet the labeling, SDS, and employee information and training requirements. It must include the list of hazardous chemicals present and your methods for informing employees about nonroutine-task hazards, such as vessel cleaning, and chemicals in unlabeled pipes.
Where employees of multiple employers may be exposed at one site, cover how other employers get on-site access to SDSs, which precautionary measures they need, and what labeling system you use.
OSHA Publication 3695 contains a free sample written program. OSHA states it is not a standard or regulation and creates no new legal obligations. Treat it as a starting structure and replace generic language with your own chemicals, locations, and procedures.
6. Train employees when it matters
Under paragraph (h)(1), employees need effective information and training at initial assignment and whenever a new chemical hazard they have not been trained about reaches their work area. Federal HazCom sets no blanket annual retraining schedule, though refreshers make sense when inspections or incidents show gaps.
Cover release detection, the hazards, protective measures, emergency procedures, labels, SDS use, and your program’s details. An employee should finish able to find an SDS, read a label, and explain what to do after a spill. A signed attendance sheet does not show practical understanding. Helios Comply handles assignment by role, completion tracking, and certificates.
7. Track the 2024 rule transition dates
OSHA updated the standard in 2024 and later extended key compliance dates. For substances, employers must update alternative workplace labels, the program, and training as necessary for newly identified hazards by November 20, 2026. For mixtures, the deadline is May 19, 2028.
Transition dates do not pause current obligations. As updated labels and SDSs arrive, read them for changed hazard information. OSHA’s HazCom rulemaking page and HazCom FAQ cover the transition.
8. Revisit the program as work changes
Review the program when you add chemicals, change a process, open a location, hire into exposed roles, bring in contractors, or get revised hazard information.
Use an OSHA inspection checklist to find gaps, then ask a qualified safety professional about your operations. Software supports the work but is not proof of compliance.
What Belongs on a GHS Shipped-Container Label?
Labels on hazardous chemicals leaving a manufacturer’s, importer’s, or distributor’s workplace require six elements under paragraph (f)(1).
|
Shipped-label element |
What it tells the reader |
|
Product identifier |
The name or number identifying the chemical |
|
Signal word |
The prescribed word showing hazard severity |
|
Hazard statement(s) |
Standardized descriptions of the hazards |
|
Pictogram(s) |
Required hazard symbols in GHS format |
|
Precautionary statement(s) |
Measures to reduce harmful exposure or improper handling |
|
Supplier identification |
Name, U.S. address, and U.S. phone number of the responsible party |
Workplace labels differ, as covered above. Use information for the actual chemical, not warnings copied from a similar product, and tie the identifier back to the SDS.
Practical HazCom Checklist
- Confirm which employees and chemicals fall in scope.
- Assign a program owner and a backup.
- Keep a current chemical list for each work area.
- Obtain an SDS for every listed chemical.
- Test SDS access on every shift and at remote jobsites.
- Inspect incoming, stationary, and secondary-container labels.
- Document nonroutine tasks and unlabeled pipes.
- Add multi-employer procedures when contractors are present.
- Train at initial assignment and when a new hazard appears.
- Note the applicable 2024 transition date.
- Recheck after chemical, process, staffing, or location changes.
OSHA’s On-Site Consultation Program offers no-cost, confidential services primarily to smaller businesses, separately from enforcement. State Plan requirements may differ, so check the rules where your employees work.
How Helios Comply Helps
Helios Comply does not write your program and does not replace it. Paragraph (e) puts a workplace-specific written program on the employer, whatever software you buy. Helios Comply supports day-to-day execution and recordkeeping between reviews.
Helios Comply centralizes chemical and SDS records, with QR-code, mobile, and offline employee access. It generates GHS secondary-container labels, keeps sites separate through location-scoped access, tracks training assignments, completion, and certificates, and compiles audit-ready reports and CSV exports.
None of that guarantees compliance, prevents a citation, or serves as legal advice. It reduces the manual work behind keeping records current. Setup help is available for the first pass.
Start Free Trial or Call (855) 920-5202
Frequently Asked Questions
Does a five-person company need a written HazCom program?
Possibly. Headcount creates no general exemption. HazCom can apply if employees may be exposed to hazardous chemicals during normal work or a foreseeable emergency. Confirm the standard’s scope and any product exemptions.
Do workplace bottles need all six GHS label elements?
Not always. A workplace label may use the five hazard-related elements without supplier contact information, or the product identifier plus general hazard information, if employees can immediately access the chemical’s specific hazard information.
Is annual HazCom training required by federal OSHA?
Not as a blanket rule. Training is required at initial assignment and when a new chemical hazard the employee has not been trained about enters the work area.
Can we keep SDSs only on a computer?
Electronic access is permitted when it creates no barriers to immediate access and SDSs stay readily accessible in each work area during every shift. Test it in realistic conditions and keep a backup.