OSHA Hazard Communication Standard

Overview: Under its federal Hazard Communication Standard (29 CFR 1910.1200), OSHA requires employers in all industries (manufacturing and non- manufacturing) exposed to hazardous substances to educate and train all workers about chemical hazards they may encounter on the job.  In 2012, OSHA revised the standard ("HazCom 2012") to align with the United Nations' Globally Harmonized System of Classification and Labeling of Chemicals (GHS), changing the classification, labeling, and safety data sheet requirements described below; full compliance with the revised standard was phased in through June 1, 2016.

Hazard communication requirements.  The Hazard Communication Standard remains one of the broadest and most significant workplace health programs, and violations of it are consistently among OSHA's most frequently cited standards each year.

Preemption of state right- to- know laws.  OSHA’s standard preempts all state or local right-to-know laws except in states where it has approved state programs.

Compliance.  Hazard communication requirements include:

• logging all chemicals and substances (as defined in the Act) into a chemical inventory;
• collecting and retaining information on every chemical hazard in the   workplace, in the form of “safety data sheets” or SDSs (formerly called “material safety data sheets” or MSDSs, prior to OSHA's 2012 GHS-aligned revision of the standard);
• labeling containers of hazardous substances with the GHS-standardized label elements: product identifier, signal word, pictogram(s), hazard statement(s), and precautionary statement(s), plus the name and address of the manufacturer or other responsible party;
• educating and training employees to understand SDSs and label elements, the nature of the hazards of each substance, how to avoid these hazards, and the warning signs associated with exposure to each substance; and
• preparing a written hazard communication plan that summarizes the employer’s approach, plan for hazard communication, and the designation of key official(s) who will be responsible for implementing and maintaining the program.