OSHA · 29 CFR 1910.1200
Do you have a written hazard communication program?
If your workplace has hazardous chemicals, OSHA requires a written program that says how you label them, where the safety data sheets are, how you train people — and a list of the chemicals by the name on the sheet. It is the second most cited OSHA standard, and the paragraph inspectors write up most often is the written program itself.
OSHA updated the standard in 2024. Employers must update labels, the program and training for substances by 2026-11-20, and for mixtures by 2028-05-19.1910.1200(j)(2)(ii) · (j)(3)(ii)
What the program has to contain
- A list of the hazardous chemicals known to be present, using the product identifier that is on each one’s safety data sheet.(e)(1)(i)
- How labels, safety data sheets and training are handled — the program has to describe how paragraphs (f), (g) and (h) are met.(e)(1)
- Non-routine tasks and unlabeled pipes — how people are told about the hazards before they do the job.(e)(1)(ii)
- Contractors on site — how another employer’s people get the sheets, the precautions and the labeling system.(e)(2)
- Sheets within reach on every shift — a binder or electronic access, as long as nothing stands between an employee and the sheet.(g)(8)
- Training at hire and whenever a new hazard arrives — not once a year, but when something new comes through the door.(h)(1)
The list is the same list
The chemical list OSHA wants is the inventory you build to find out whether you have to file Tier II — product names, CAS numbers, hazard classes from section 2 of the sheet, where each one is kept. Whether or not you are over a Tier II threshold, that list gives you the written program: we fill in the sections the rule requires, in the structure of the state sample programs, and leave visible blanks only where the answer is yours — where the binder is, who runs the program, which non-routine tasks you do.
We do not store your safety data sheets, and we do not write training. The program says where the sheets are and what training covers; keeping both is yours.
Start with the chemical list — freeThe list is free. The program, the kept list and the reminders are the HazCom program plan — $99 a year. If you also have to file Tier II, the file is the Single facility plan.
What we have not read yet
Twenty-two states run their own OSHA-approved plans with their own version of this rule. Each is at least as protective as the federal text, which is what the program follows. We have not read the state versions yet, and the program says so on its first page.