OSHA Hazard Communication Program template

A written Hazard Communication Program (HazCom) explains how a workplace will identify and communicate hazardous-chemical information through labels, safety data sheets (SDS) and employee information and training. A chemical list and a binder of SDS alone do not make a complete program. Under 29 CFR 1910.1200(e), a covered employer must develop, implement and maintain a written program at each workplace. It must describe how the label, SDS and training requirements will be met and include the required chemical list and methods for informing employees about non-routine tasks and chemicals in unlabeled pipes. Additional communication methods are required for certain multi-employer workplaces.

Use the fillable framework below as a starting document. Enter actual chemicals, tasks, labels, SDS access and training arrangements; then test whether workers can use them. The employer should check whether federal OSHA, an OSHA-approved state plan or sector-specific rules govern its site, and seek competent advice for technical hazards. This template is not a substitute for exposure controls, respiratory protection, spill response or any other program that the chemicals or work may require.

1. Program identity and responsibility

The coordinator maintains the program, but supervisors and workers need to know their parts. State who approves a new chemical, who updates the list and SDS, who checks secondary-container labels, who trains new or reassigned staff and who tells contractors about shared exposures. If electronic access is used, decide what happens during an outage or when employees work away from the main office.

2. List of hazardous chemicals

The written program must include a list of hazardous chemicals known to be present using the product identifier referenced on the appropriate SDS. OSHA permits a workplace-wide or work-area list. Do not list only the products purchased this month; include relevant chemicals used, stored or present in the covered work areas. Check whether a product falls within an exemption before excluding it.

The added hazard-category and owner columns help manage the program; they do not replace the SDS. Reconcile the list with a physical walk-through, stores, maintenance areas and products brought by contractors. Keep the product identifier consistent across the container, list and SDS so a worker can find the right information quickly. Review on a new product, reformulation, discontinued product or changed work area.

3. Labels and other warnings

Shipped containers: [Who checks incoming labels; where damaged/missing labels are reported; what happens before an unlabeled container is used]. Workplace/secondary containers: [System used, responsible person and how employees understand it]. Stationary process containers: [How applicable signs/placards/process sheets are used and where they are available]. Portable immediate-use containers: [Procedure where an OSHA exception actually applies].

The program should say how the site's label method gives workers the required hazard information. Employees must know what product is in a container and how to find its hazards. Do not instruct workers to rely on color alone or to guess at the contents of an unmarked bottle. Chemical manufacturers and importers have distinct shipped-container duties; an employer's workplace-label system must still meet the applicable OSHA provisions. See 29 CFR 1910.1200(f) for the exact text.

Example site rule: A worker who pours a solvent into a reusable process container checks the product and applies the approved workplace label before anyone else may use it. If the container's identity or hazard information cannot be confirmed, the container is isolated under the site's procedure and the supervisor resolves it. Adapt the rule to the actual process and any relevant exception.

4. Safety data sheets: obtain, maintain and provide access

OSHA's SDS provisions in 1910.1200(g) govern maintenance and access. A QR code that fails without reception is not useful access for a remote crew. Test the procedure by asking a worker to retrieve the SDS for a real product during the shift. Keep the current document identifiable; do not silently substitute a generic SDS for a different formulation.

5. Employee information and training

Who receives instruction: [Roles/areas with hazardous chemicals, including new hires and reassignment]. When: [At initial assignment and when a new chemical hazard is introduced into the work area, consistent with OSHA's training rule]. Who delivers it: [Competent person and language/accessibility arrangements]. How understanding is checked: [Demonstration, questions or other method]. Where recorded: [Training log].

The content should include where chemicals are present, where the written program and SDS can be found, how to recognise a release, the physical and health hazards, protective measures, emergency procedures, and how to read labels and SDS. OSHA allows training by hazard categories where appropriate, but chemical-specific information must remain available through labels and SDS. A generic slideshow without site products, tasks or worker understanding is a weak implementation.

Training record fields: Worker [ ]; role/work area [ ]; date [ ]; topics and products/hazards covered [ ]; trainer [ ]; language/method [ ]; questions or demonstration [ ]; follow-up needed [ ]. The written program should explain the process; the record shows that it happened. Avoid claiming a single universal annual retraining frequency under HazCom when the standard's trigger is tied to initial assignment and newly introduced chemical hazards.

6. Non-routine tasks and unlabeled pipes

Paragraph (e)(1)(ii) requires methods to inform employees about hazards of non-routine tasks and chemicals in unlabeled pipes in their work areas. Enter the actual method, not just “consult supervisor.”

HazCom communication does not replace a confined-space permit, lockout/tagout, respiratory-protection program or chemical-specific standard where those apply. Identify the linked procedure and person who verifies it. If a pipe is unlabeled, the program needs a reliable way to tell affected workers its contents and hazards before the work exposes them.

7. Other employers and contractors on site

At a multi-employer workplace where this employer's chemicals may expose another employer's employees, paragraph (e)(2) requires the program to describe how the other employer will get SDS access, be informed of necessary precautions in normal and foreseeable emergency conditions, and be informed of the site's labeling system.

Who communicates: [Name/role]. Before work: [Exchange chemicals/areas/tasks, SDS access, labels, emergency procedures]. If conditions change: [How and to whom changes are communicated]. Record: [Meeting/permit/induction or handoff record]. Ask contractors about the hazardous chemicals they bring and assess the shared exposure, while distinguishing this site's duties from the contractor's own program. A contract clause alone does not teach the people doing the work what a label means or where to find an SDS.

8. Review and implementation checks

Review the program when chemicals, processes, SDS information, work areas, contractors or applicable rules change. Periodically test whether the inventory matches the workplace, labels are readable, SDS access works on every shift, workers can explain the hazards and controls, and non-routine/multi-employer communication occurs in practice. Assign corrective actions with owners and due dates. Make the written program available on request as OSHA requires.

Review log: Date [ ]; trigger [ ]; products/tasks checked [ ]; gaps [ ]; interim safeguard [ ]; action owner/due date [ ]; revision approved [ ]; employees/other employers told [ ]; verification [ ].

2024 HCS update and 2026 extension

OSHA updated the Hazard Communication Standard in 2024 and extended its phase-in compliance dates on 15 January 2026. Employers updating workplace labels, their written program or employee training may be affected as revised classifications and SDS/labels arrive. The deadlines differ for substances and mixtures and for manufacturers/importers/distributors versus employers. This template deliberately does not hard-code a deadline table: verify the current OSHA phase-in schedule and the chemicals supplied to the workplace on publication and implementation day. Do not claim every existing SDS became invalid on one date, or that a software upload alone completes required training.

The existing Complys US pricing page describes document storage and other compliance features, but this writer pass has not confirmed a HazCom program workflow in the implementation. Add a product CTA only to an exact verified live US route and describe only functions that work. Complys cannot classify a chemical, author an SDS or make a workplace HazCom-compliant without the employer's review and action.

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