Policy required document Workplace
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 the 2028 deadline after chemical manufacturers finish relabeling.
Obligation ledger
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 July 19, 2028 (after the extension). Substances upstream by May 19, 2026; mixtures by November 19, 2027. Legally required; dates per Federal Register notice. Verify. | 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
What changed
Change log.
Frameworks
Where this document is required.
Who looks at it
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 |
|---|---|
| ISNetworld/Avetta | Platform reviewers (ISN's RAVS team, Avetta's review specialists) grading documents against client and regulatory checklists; hiring clients may additionally audit contractors in the field. No independent certification or accreditation exists |
| ISO 9001 | Accredited certification body (registrar) accredited to ISO/IEC 17021-1 for quality management systems |
| 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 |
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Consultants.
Firms that name these standards in their own material.
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Where it lives
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From the publisher
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Questions
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 July 19, 2028. 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.
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