Written hazard communication program requirements and free template

If your workers can be exposed to hazardous chemicals, OSHA requires a written hazard communication program (a HazCom program) at each workplace. It is a short document that explains how you handle labels, safety data sheets (SDS) and training, and it carries the list of hazardous chemicals on site.

This guide walks through what 29 CFR 1910.1200 paragraph (e) requires, one paragraph at a time. Then it gives you a fill-in template, a chemical inventory form and a briefing checklist you can copy. Every rule below is cited to the exact paragraph. Construction follows the same rule: 29 CFR 1926.59 says the requirements for construction work are identical to those in 1910.1200.

This is a plain-language guide, not legal advice. When a line matters to you, read the paragraph itself.

What a written hazard communication program is

The Hazard Communication Standard works as one chain. Chemical makers classify the hazards and pass the information down on labels and safety data sheets. Employers pass it on to their workers. The standard says this happens through "comprehensive hazard communication programs, which are to include container labeling and other forms of warning, safety data sheets and employee training" (29 CFR 1910.1200(a)(1)).

The written program is the part on paper. It does not replace labels, SDSs or training. It says how you handle each one at your workplace, and it includes the list of hazardous chemicals you have.

Most employers only use chemicals. They do not make or import them. For them the standard is clear about where to focus: employers who do not produce or import chemicals "need only focus on those parts of this rule that deal with establishing a workplace program and communicating information to their workers" (29 CFR 1910.1200(b)(1)).

Who needs one

• Any employer whose workers can be exposed. The standard applies to any chemical "known to be present in the workplace in such a manner that employees may be exposed under normal conditions of use or in a foreseeable emergency" (29 CFR 1910.1200(b)(2)).
• What counts as hazardous. A hazardous chemical is "any chemical which is classified as a physical hazard or a health hazard, a simple asphyxiant, combustible dust, or hazard not otherwise classified" (29 CFR 1910.1200(c)).
• Construction contractors. Same requirements, through 29 CFR 1926.59.
• Office staff, usually not. The definition of employee leaves out "office workers or bank tellers who encounter hazardous chemicals only in non-routine, isolated instances" (29 CFR 1910.1200(c)). A custodian or a print shop worker is a different story.
• Labs and sealed containers, in a limited way. Laboratories follow a shorter list in 29 CFR 1910.1200(b)(3), and they also have their own standard. Where workers only handle sealed containers that are not opened in normal use, such as warehousing or retail sales, the standard applies only as listed in 29 CFR 1910.1200(b)(4): keep incoming labels on, keep the SDSs that come with shipments (and get one if a worker asks for it), and train workers to protect themselves if a container spills or leaks.
• Some products are outside the standard. 29 CFR 1910.1200(b)(6) lists them. Examples include articles, tobacco, food for personal use, and consumer products used for the purpose the maker intended, with exposure no greater than a consumer would have. Be careful with that last one. A cleaner used all shift by a custodian is not used the way a homeowner uses it. When in doubt, list the product and keep its SDS.

What 29 CFR 1910.1200(e) requires, paragraph by paragraph

Paragraph (e) is short. Here is each part in plain words, and the section of the template below where you cover it.

Develop it, implement it, maintain it

The core sentence is in 29 CFR 1910.1200(e)(1): "Employers shall develop, implement, and maintain at each workplace, a written hazard communication program". Each verb matters.

• Develop means it exists on paper.
• Implement means the crew actually works the way the paper says.
• Maintain means it stays current when products, tasks or people change.

The program must at least describe how you meet the rules for labels and other forms of warning (paragraph (f)), safety data sheets (paragraph (g)) and employee information and training (paragraph (h)) (29 CFR 1910.1200(e)(1)).

The words at each workplace matter for contractors. The standard defines a workplace as "an establishment, job site, or project, at one geographical location containing one or more work areas" (29 CFR 1910.1200(c)). Each jobsite is its own workplace, so the chemical list for one job will not match the next one.

The list of hazardous chemicals

The program must include "a list of the hazardous chemicals known to be present using a product identifier that is referenced on the appropriate safety data sheet" (29 CFR 1910.1200(e)(1)(i)). The list can cover the whole workplace or each work area.

Use the exact product name or number from the SDS. The product identifier "shall permit cross-references to be made among the list of hazardous chemicals required in the written hazard communication program, the label and the SDS" (29 CFR 1910.1200(c)). In plain words: a worker holding a can should find it on your list, and find its SDS, without guessing.

Non-routine tasks and unlabeled pipes

The program must state "the methods the employer will use to inform employees of the hazards of non-routine tasks" and of the chemicals "contained in unlabeled pipes in their work areas" (29 CFR 1910.1200(e)(1)(ii)).

The standard's own example of a non-routine task is cleaning reactor vessels. In a shop or on a jobsite, think of work done once a month or once a year: stripping a floor, cleaning out a tank or a sump, flushing a cooling system, using a new adhesive in a small room. Write down who briefs the crew before those jobs and what the briefing covers. The checklist further down gives you a format.

Multi-employer workplaces

This part applies when you "produce, use, or store hazardous chemicals at a workplace in such a way that the employees of other employer(s) may be exposed" (29 CFR 1910.1200(e)(2)). The standard's example is the employees of a construction contractor working on site. Your program must then also describe how you will:

1. give the other employers access to the SDSs for each hazardous chemical their workers may be exposed to (29 CFR 1910.1200(e)(2)(i)),
2. tell them about the precautions needed in normal operations and in foreseeable emergencies (29 CFR 1910.1200(e)(2)(ii)),
3. tell them about the labeling system you use (29 CFR 1910.1200(e)(2)(iii)).

On a construction site this runs in every direction. The painting sub brings solvents. The concrete sub brings form release and curing compound. The general contractor may store fuel. Every employer whose chemicals can reach another crew has to cover those three points. A shared SDS station in the site trailer and a short chemical exchange at the subcontractor kickoff make it easy. See multi-employer worksites for a crew talk and the site safety plan template for where this fits in a site plan.

Building on an existing program

You may rely on an existing hazard communication program as long as it meets the criteria in paragraph (e) (29 CFR 1910.1200(e)(3)). If your company already has one, update it rather than starting over.

Who can ask to see it

You must make the written program available, upon request, to employees, their designated representatives, the Assistant Secretary (the head of OSHA) and the Director (the head of NIOSH), in line with 29 CFR 1910.1020(e) (29 CFR 1910.1200(e)(4)). Workers must also be told where the written program, the chemical list and the SDSs are (29 CFR 1910.1200(h)(2)(iii)).

Crews that move between sites

When employees travel between workplaces during a shift, the written program may be kept at the primary workplace facility (29 CFR 1910.1200(e)(5)). SDSs may be kept there too, but the employer must make sure employees "can immediately obtain the required information in an emergency" (29 CFR 1910.1200(g)(9)). For service techs, landscapers and other mobile crews, that usually means an SDS binder or a reliable app in each truck.

The three things your program must describe

Labels and other forms of warning

• Shipped containers. The manufacturer, importer or distributor labels them with the product identifier, signal word, hazard statements, pictograms, precautionary statements, and the name, U.S. address and U.S. phone number of the responsible party (29 CFR 1910.1200(f)(1)).
• Keep those labels on. You may not remove or deface labels on incoming containers unless the container is immediately marked with the required information (29 CFR 1910.1200(f)(9)).
• Workplace containers. Each container of hazardous chemicals in the workplace must be labeled, tagged or marked with either the shipped-label information in (f)(1)(i) through (v), or the product identifier plus words, pictures or symbols that give at least general information about the hazards (29 CFR 1910.1200(f)(6)). The second option only works together with the rest of your program, so the specific hazards stay easy to find.
• Stationary process containers. Signs, placards, process sheets, batch tickets or operating procedures may be used instead of a label on each container, as long as they identify the containers, carry the required label information and are readily accessible during each shift (29 CFR 1910.1200(f)(7)).
• Portable containers. No label is needed on a portable container filled from a labeled container when it is "intended only for the immediate use of the employee who performs the transfer" (29 CFR 1910.1200(f)(8)). Immediate use means the chemical stays under the control of the person who transferred it and is used only by that person, within the same shift (29 CFR 1910.1200(c)). A spray bottle left in the gang box overnight, or handed to a coworker, needs a label.
• Language. Workplace labels must be legible, in English, and prominently displayed on the container or readily available in the work area during each shift. Employers with workers who speak other languages may add that language, as long as the information is in English as well (29 CFR 1910.1200(f)(10)).

The standard designates eight pictograms (29 CFR 1910.1200(c)), and its Appendix C assigns label elements to each hazard class and category. The signal word is either "danger" for the more severe hazards or "warning" (29 CFR 1910.1200(c)).

In the program, say which workplace labeling system you use and who checks labels. The free chemical labels and pictograms talk shows each pictogram and teaches the crew how to read a label.

Safety data sheets

• One SDS per hazardous chemical you use. "Employers shall have a safety data sheet in the workplace for each hazardous chemical which they use" (29 CFR 1910.1200(g)(1)).
• Reachable during the shift. Copies must be "readily accessible during each work shift to employees when they are in their work area(s)" (29 CFR 1910.1200(g)(8)). Electronic access is allowed as long as it creates no barrier to immediate employee access.
• Any form. SDSs may be kept in any form, including as operating procedures, and may be grouped by process, as long as the required information is there for each hazardous chemical (29 CFR 1910.1200(g)(10)).
• Same 16 sections, same order. Every SDS runs from Section 1, Identification, to Section 16, Other information, which includes the date of preparation or last revision (29 CFR 1910.1200(g)(2)). Workers must be trained on that order and on how to use it (29 CFR 1910.1200(h)(3)(iv)).
• English first. The SDS must be in English, and the employer may keep copies in other languages as well (29 CFR 1910.1200(g)(2)).

In the program, name where the SDSs are kept (binder, site trailer, app), who gets the SDS for each new product, and what happens when one is missing. The safety data sheets talk walks a crew through the 16 sections in five minutes.

Employee information and training

When. Training is required at the time of initial assignment, and whenever a new chemical hazard the employees have not been trained about is introduced into their work area (29 CFR 1910.1200(h)(1)). It may cover categories of hazards, such as flammability, or specific chemicals. Chemical-specific information must always be available through labels and SDSs.

Information workers must get (29 CFR 1910.1200(h)(2)):

• the requirements of the standard,
• any operations in their work area where hazardous chemicals are present,
• where the written program, the chemical list and the SDSs are, and how to get them.

Training must include at least (29 CFR 1910.1200(h)(3)):

• how to detect the presence or release of a hazardous chemical, such as monitoring, continuous monitors, or how it looks or smells when released,
• the physical, health, simple asphyxiation, combustible dust and pyrophoric gas hazards of the chemicals in the work area, and hazards not otherwise classified,
• what workers can do to protect themselves, including your work practices, emergency procedures and PPE,
• the details of your program: the labels on shipped containers, your workplace labeling system, the SDS and its order of information, and how to get and use the hazard information.

The standard asks for "effective information and training" (29 CFR 1910.1200(h)(1)). If your crew works in Spanish, training in Spanish is the practical way to make it effective. The mixed-language crews talk has tips for running it with a split crew.

1910.1200 does not spell out a training record. Keep one anyway. A sign-in sheet with the date, topic, trainer and signatures is how you show the training happened.

A five-minute talk on labels or SDSs is a good refresher between trainings, but by itself it does not cover everything paragraph (h)(3) lists. For running short talks well, see how to run a toolbox talk.

The 2024 update and the dates to know

The standard was updated to line up with the United Nations Globally Harmonized System (GHS), "primarily Revision 7" (29 CFR 1910.1200(a)(1)). The current version became effective July 19, 2024 (29 CFR 1910.1200(j)(1)).

For employers who use chemicals, two deadlines matter. As necessary, you must update any alternative workplace labeling used under (f)(6), update the hazard communication program, and give any additional training for newly identified hazards:

• for substances, no later than November 20, 2026 (29 CFR 1910.1200(j)(2)(ii)),
• for mixtures, no later than May 19, 2028 (29 CFR 1910.1200(j)(3)(ii)).

During the transition, employers may comply with either the current section or the version revised as of July 1, 2023, or both (29 CFR 1910.1200(j)(4)).

In practice: when updated SDSs and labels arrive with new hazard information, swap the SDS in your file, update your workplace labels and the chemical list, and brief the crew on what changed.

How to write your program in seven steps

1. Name one owner. One person keeps the program, the chemical list and the SDS file current, with a backup. Put both names and phone numbers at the top.
2. Walk every work area. Open cabinets, gang boxes, truck beds, the maintenance shop, the janitor closet and the break room. List every product: fuels, aerosols, adhesives, sealants, paints, cleaners, and anything someone brought from the hardware store.
3. Match each product to a current SDS. Use the product identifier from the SDS on your list (29 CFR 1910.1200(e)(1)(i)). If an SDS is missing, request it from the supplier and decide what happens to the product until it arrives.
4. Pick your workplace labeling system (29 CFR 1910.1200(f)(6)). Keep it simple enough that a new hire understands it on day one.
5. Fill in the template below. Delete what does not apply. Add what is specific to your site.
6. Train before first exposure and whenever a new hazard comes in (29 CFR 1910.1200(h)(1)). Record who attended.
7. Keep it alive. Update it when you add a product, change a process, start a new job, bring in a new sub or get updated SDSs.

Free written hazard communication program template

Copy this into your own document and replace everything in brackets. Keep the citations; they show an inspector or a client which rule each section answers.

Written hazard communication program

• Company: [company name]
• Workplace or jobsite: [name and address]
• Program owner: [name, title, phone]
• Backup: [name, phone]
• Date written: [date]. Last reviewed: [date].
• Where this program, the chemical list and the SDSs are kept: [location, binder or app]

1. Purpose and scope. [Company] has written this program to meet 29 CFR 1910.1200 [and 29 CFR 1926.59 for construction work]. It covers every employee who may be exposed to hazardous chemicals under normal conditions of use or in a foreseeable emergency at [workplace]. [If you are updating an existing program, say so; 29 CFR 1910.1200(e)(3) allows it as long as it meets paragraph (e).]

2. Responsibilities.

• Program owner: keeps this program, the chemical list and the SDS file current, arranges training and answers questions.
• Supervisors and foremen: make sure containers in their area are labeled, the crew knows where the SDSs are, and new products are reported before anyone uses them.
• Purchasing, or whoever buys chemicals: gets the SDS with every new product and gives it to the program owner.
• Employees: read labels and SDSs, use the listed PPE, and report unlabeled containers, leaks, spills and symptoms.

3. List of hazardous chemicals. The list of hazardous chemicals at this workplace is in Appendix A. Each product is listed by the product identifier on its SDS, so the list, the label and the SDS match (29 CFR 1910.1200(e)(1)(i)). [Program owner] updates the list whenever a product is added or removed.

4. Labels and other forms of warning.

• Shipped containers keep the manufacturer's label. Nobody removes or defaces a label unless the container is immediately relabeled (29 CFR 1910.1200(f)(9)).
• Workplace containers are labeled with [the full shipped-label information, or the product identifier plus pictograms and hazard words] (29 CFR 1910.1200(f)(6)).
• Stationary process containers: [describe the signs, placards or batch tickets used, or write "none"] (29 CFR 1910.1200(f)(7)).
• A portable container filled for immediate use by the person who filled it does not need a label (29 CFR 1910.1200(f)(8)). Any container left for the next shift or handed to someone else gets a label.
• Labels are in English. [Spanish or another language] is added on [which labels] (29 CFR 1910.1200(f)(10)).
• [Name] checks labels during [the weekly inspection or daily walk].

5. Safety data sheets.

• An SDS is kept for every product on the chemical list (29 CFR 1910.1200(g)(1)).
• SDSs are kept at [location or locations] and are available to employees in their work area during every shift (29 CFR 1910.1200(g)(8)). [If electronic: name the device or app, and the backup when there is no signal.]
• Crews working away from the main facility reach SDSs by [method] and can get the information immediately in an emergency (29 CFR 1910.1200(g)(9)).
• When an SDS is missing or out of date, [name] requests it from [supplier]. Until it arrives, [say what happens to the product].

6. Employee information and training.

• Employees are trained at initial assignment and whenever a new chemical hazard is introduced into their work area (29 CFR 1910.1200(h)(1)).
• Training covers the items in 29 CFR 1910.1200(h)(2) and (h)(3): the requirements of the standard, where hazardous chemicals are used in their area, where this program and the SDSs are kept, how to detect a release, the hazards of the chemicals in their work area, protective measures (work practices, emergency procedures, PPE), and how to read our labels and SDSs.
• Training is given in [English and Spanish, or the languages the crew uses] by [name or role]. Attendance is recorded on a sign-in sheet kept for [period].

7. Hazardous non-routine tasks. Before a non-routine task such as [list tasks], the supervisor briefs the workers on the chemical hazards, the SDS, the controls, the PPE and the emergency steps for that task (29 CFR 1910.1200(e)(1)(ii)). The briefing is recorded on [form].

8. Chemicals in unlabeled pipes. Workers are told about chemicals in unlabeled pipes in their work areas by [pipe markings, drawings or a supervisor briefing before work on piping] (29 CFR 1910.1200(e)(1)(ii)). [If there are no such pipes, write that.]

9. Other employers on site. When another employer's workers may be exposed to our chemicals (29 CFR 1910.1200(e)(2)):

• They get access to our SDSs by [method].
• We tell them about precautions for normal work and foreseeable emergencies by [method, for example the kickoff meeting].
• We explain our labeling system by [method].
• Contractors who bring chemicals onto our site give [name] their chemical list and SDSs before they start work.

10. Availability of this program. This program is available on request to employees, their designated representatives, OSHA and NIOSH (29 CFR 1910.1200(e)(4)). [For crews that travel: it is kept at (primary facility) (29 CFR 1910.1200(e)(5)).]

11. Program review. [Program owner] reviews this program when a new chemical, process or task is introduced, when updated SDSs or labels arrive, after any spill or exposure, and at least [once a year]. Review log: [date, name, what changed].

Appendices. A: chemical inventory. B: training sign-in sheets. C: non-routine task briefings.

Chemical inventory form (Appendix A)

Tips for filling it in:

• One row per product, not per container.
• Copy the hazards from SDS Section 2, Hazard(s) identification (29 CFR 1910.1200(g)(2)(ii)). Do not guess them from the product name.
• Check the date in Section 16 (29 CFR 1910.1200(g)(2)(xvi)) so you know which version you have.
• A gas can is a container. Fuel in a vehicle's own tank is not: the definition of container excludes "engines, fuel tanks, or other operating systems in a vehicle" (29 CFR 1910.1200(c)).
• Products that crews bring from other jobs count once they are on your site.

Non-routine task briefing checklist (Appendix C)

Use this before any chemical task the crew does not do every day.

• Task, date, location and the names of the crew.
• Chemicals involved, with the SDS sections on hazards (2), first aid (4), spills (6), handling (7) and protection (8) read out loud.
• How a release would be noticed: smell, look, monitor or alarm.
• Controls: ventilation, isolation, permits if the space or the job needs one.
• PPE for this task, checked before starting.
• Emergency plan: where the eyewash and the spill kit are, who calls for help, where to go. Where the eyes or body may be exposed to injurious corrosive materials, facilities for quick drenching or flushing must be provided within the work area (29 CFR 1910.151(c)).
• Signatures of the supervisor and the crew.

Common gaps in written HazCom programs

• The chemical list does not match what is on the shelf. Products were added after the program was written, or workers brought their own.
• Names on the list do not match the SDS product identifiers, so nobody can find the right sheet.
• The SDSs are in the office while the crew is on the jobsite with no way to reach them during the shift.
• Old material safety data sheets in the old format are still in the binder. Replace them with the current SDS from the supplier.
• Spray bottles and fuel cans with no label. The portable container exception only covers immediate use by the person who filled it.
• Nothing written about non-routine tasks or piping.
• No method for sharing SDSs, precautions and the labeling system with subs or other employers on site.
• Training at hire and never again, even after new products came in.
• Training given in a language part of the crew does not follow well.
• No update for the 2024 changes, with the November 20, 2026 and May 19, 2028 dates in paragraph (j).
• Workers cannot say where the program is kept, even though they must be told (29 CFR 1910.1200(h)(2)(iii)).

Chemicals with their own standards

Some chemicals also have their own standard with extra rules for training, monitoring or written plans. Lead, crystalline silica and asbestos are common on construction and renovation work. Laboratories that use hazardous chemicals need a written chemical hygiene plan (29 CFR 1910.1450(e)(1)), and hazardous waste operations fall under 29 CFR 1910.120. Your HazCom program still covers the labels, SDSs and basic training for those products. See lead exposure, crystalline silica, asbestos awareness and HAZWOPER awareness.

Free talks and tools for your HazCom program

Each of these topic pages has a free five-minute talk in English and Spanish with a printable PDF and a sign-in table:

• Hazard communication (HazCom)
• Safety data sheets (SDS)
• Chemical labels and pictograms
• Chemical handling
• Cleaning chemicals
• Chemical spill response
• Chemical burns and corrosives
• Solvent safety and flammable liquids
• Eyewash stations, skin protection and respiratory protection
• New worker orientation and temporary workers, for the people who most often miss HazCom training

To see which other standards require training for your crew's tasks, use the OSHA training requirements finder or read OSHA training requirements by job. If you are building the rest of your safety paperwork, the written safety program template shows where HazCom fits.

If you want HazCom training ready to run, ToolboxKits sells a $4.99 talk kit (talk in English and Spanish, sign-in sheet and short quiz) and a $9 training kit with an editable PowerPoint, trainer notes, a 10-question quiz and a certificate. No subscription. See pricing.