• The written hazard communication program must include information on labels and other forms of warning, SDSs, and training.
• In work operations where employees only handle chemicals in sealed containers which are not opened under normal conditions of use, a written hazard communication program is not required, although these operations have other responsibilities under 1910.1200(b)(4).

Summary of requirements

All employers with employees who are exposed or potentially exposed to hazardous chemicals known to be present in their workplaces, must develop, implement, and maintain at each workplace a written hazard communication program that includes labeling and other forms of warning, safety data sheets (SDSs), and training.

Employers on multi-employer worksites who do not use hazardous chemicals, but whose employees are exposed to the chemicals used by other employers on the worksite, are required to have a program and train their employees on the hazards of the chemicals in the work areas.

The Occupational Safety and Health Administration (OSHA) will be looking for the following elements in a written program to ensure compliance with the HazCom standard:

• A list of the hazardous chemicals known to be present in the workplace that matches the identifier on the container label and the SDS.
• Designation of person(s) responsible for ensuring labeling of in-plant containers.
• Designation of person(s) responsible for ensuring labeling of shipped containers (if any).
• Description of any in-plant labeling system(s) (if used).
• Description of any labeling alternatives used in the facility (if any).
• Description of HazCom training provided to employees.
• Procedures to review and update label information when necessary.
• Methods used to inform employees of the hazards of non-routine tasks.
• Methods used to inform employees of the hazards of unlabeled pipes in their work areas.
• How the employer will comply on multi-employer worksites.

Exempt workplaces

In work operations where employees only handle chemicals in sealed containers which are not opened under normal conditions of use, such as in warehouses or consumer outlets, a written hazard communication program is not required. However, these operations have other obligations under the standard at 1910.1200(b)(4).

Laboratories, whether completely or partially exempt from the HazCom standard, do not need to complete a written program, even if other portions of the standard apply. See 1910.1200(b)(3).