Smarter HR SolutionsHouston, TX
- What they do
- Compliance consulting
- Who they help
- Its website offers consulting for employee handbooks, HR policies, HR compliance audits and OSHA written programs.
- Standards
- Pricing
- Not published
Hazard Communication Program
OSHA's Hazard Communication Standard requires any employer whose workers may be exposed to hazardous chemicals to keep a written program at the workplace.
The program is short by design: it names who maintains the chemical inventory, how containers are labeled, how safety data sheets are obtained and made available, how employees are trained, and how non-routine tasks and multi-employer sites are handled. The inventory itself, the SDS binder or database, and the training records are the attachments that make it real.
HazCom is the most frequently cited OSHA standard year after year, and the written program is the first thing a compliance officer requests.
The 2024 update to the standard (aligning to GHS Revision 7) changed label and SDS content; employers must update their written programs and training by November 20, 2026 for substances and May 19, 2028 for mixtures, after chemical manufacturers finish relabeling.
Also called: HazCom program, Written hazard communication program, Right-to-know program, GHS program
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Who requires it, and what each one says.
| Source | Applies when | What it requires | Status |
|---|---|---|---|
| OSHA Hazard Communication Standard, written program 29 CFR 1910.1200(e) | Hazardous chemicals are present in the workplace | A written program describing how labels, SDSs and training are handled, a list of hazardous chemicals, methods for non-routine tasks and for informing other employers on multi-employer sites. Legally required. | Mandatory |
| OSHA Hazard Communication Standard, training 29 CFR 1910.1200(h) | At initial assignment and when a new hazard is introduced | Effective information and training on the standard, operations with hazardous chemicals, the location of the written program and SDSs, hazard detection, protective measures, and the labeling system. Legally required. | Mandatory |
| HCS 2024 final rule and extension 89 FR 44144 (May 20, 2024); extension at 91 FR (Jan 15, 2026) | All covered employers | Update workplace labeling, the written program and training for any new hazard information by November 20, 2026 for substances and May 19, 2028 for mixtures (after the extension). Manufacturers, importers and distributors: substances by May 19, 2026; mixtures by November 19, 2027. Legally required; dates per 29 CFR 1910.1200(j). | Mandatory |
| Construction HazCom 29 CFR 1926.59 | Construction employers | Incorporates 1910.1200 by reference. Legally required. | Mandatory |
| ISNetworld RAVS and Avetta reviews Client-specific RAVS questionnaires | You bid work through a contractor prequalification network | Upload of the written HazCom program; graded against OSHA elements and the hiring client's additions. Contractual, not law. | Market |
Required sections
- Purpose and scope, including who is responsible for the program
- Chemical inventory: list of hazardous chemicals by product identifier, cross-referenced to SDSs (1910.1200(e)(1)(i))
- Labels and other forms of warning: how shipped-container labels are checked and how workplace containers are labeled (1910.1200(f))
- Safety data sheets: how they are obtained, where they are kept, how employees access them during each shift (1910.1200(g))
- Employee information and training: content, timing, who delivers it (1910.1200(h))
- Methods for hazards of non-routine tasks (1910.1200(e)(1)(ii))
- Hazards of chemicals in unlabeled pipes (1910.1200(e)(1)(ii))
- Multi-employer workplaces: how on-site contractors receive SDS access, precautions, and the labeling system (1910.1200(e)(2))
- Availability of the written program to employees and their representatives (1910.1200(e)(4))
- Trade secret handling where applicable (single source, 1910.1200(i))
- Program review date and change log (best practice; not stated in the standard)
What the examiner asks for
Written planThe written program itself, dated, with the chemical inventory attached or referenced. Safety consultants write it; contractor-compliance consultants tune it for RAVS; policy tools hold versions
AttestationTraining rosters with names, dates, and content covered; sign-in for new hazard training. The standard does not require a certification form, but inspectors ask for proof of who was trained when. Safety training vendors, LMS, policy tools
Operational recordsSDS binder or electronic system with every chemical on the inventory; label audits; contractor notification records. SDS management vendors, EHS software, the employer
Technical controlsNone specific. Electronic SDS access counts only if it is reliable and employees know how to use it during every shift. SDS management vendors
Change log.
2026-01-15OSHA extended HCS 2024 compliance dates by four months: manufacturers, substances May 19, 2026 and mixtures Nov 19, 2027; employer label, program and training updates, substances Nov 20, 2026 and mixtures May 19, 2028.
2024-07-19HCS 2024 final rule effective (published May 20, 2024).
2016-06-01Employers required to have updated written programs and workplace labeling for HCS 2012 (GHS Revision 3).
2013-12-01Deadline for training employees on GHS labels and the 16-section SDS format.
Where this document is required.
Where this document gets checked.
No one certifies a document like this on its own. It is read during the audits and inspections below, and by the agency behind each rule.
| Where it is looked at | Who looks at it |
|---|---|
| OSHA written programs | OSHA compliance safety and health officers, or State Plan inspectors (government inspection). No certification exists; voluntary recognition programs such as VPP and SHARP involve OSHA or consultation program evaluation |
Consultants.
Firms that name these standards in their own material.
Listed in random order, reshuffled each time the page loads. Firms that pay for a listing are shown at the top, labeled Sponsored.
Passio PEO and HR ConsultingEnglewood, CO, USA
- What they do
- Compliance consulting
- Who they help
- Its website offers consulting for OSHA compliance, Employee handbooks and HR policies, Employment law compliance, Harassment prevention training.
- Standards
- Pricing
- Not published
GreenLine HR Consulting LLCMeadville, PA, USA
- What they do
- Compliance consulting
- Who they help
- Its website offers consulting for OSHA compliance, Employee handbooks and HR policies, Employment law compliance, HR compliance audit.
- Standards
- Pricing
- Not published
Upstream Solutions, LLCUSA
- What they do
- Compliance consulting
- Who they help
- Its website offers consulting for OSHA compliance, Employee handbooks and HR policies, Employment law compliance.
- Standards
- Pricing
- Not published
Software.
Tools that hold documents like this one and record who has read them.
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What people ask.
How long should the written program be?
Most small-employer programs run three to eight pages plus the chemical inventory. OSHA's model program in Appendix E of the standard is the reference; length is not a compliance factor, coverage of each (e)(1) element is.
Do I need to rewrite the program for HCS 2024?
You need to update it for any new label elements or hazard classes that appear on the SDSs you receive, and retrain on those changes, by November 20, 2026 for substances and May 19, 2028 for mixtures. If your chemicals do not change classification, the edits are small.
Is an electronic SDS system acceptable?
Yes, if employees have immediate access in their work area during each shift and know how to use it. Backup for outages should be described in the program.
What if I am a contractor uploading to ISNetworld?
RAVS grades the written program against OSHA elements plus the client's own checklist. A program that passes OSHA can still fail a RAVS review for a missing client-specific statement. Read the client's requirements before uploading.