Hazard Communication Purpose

The purpose is to make sure hazards of all chemicals produced or imported are classified and that hazard information is passed to employers and employees. This is stated in 1910.1200(a)(1), which explains the standard implements the Globally Harmonized System (GHS) so workers know chemical hazards and protective measures.

A workplace hazard communication program must be written and include a list of hazardous chemicals present, labels and other warnings, safety data sheets, and employee training on hazards and protections. See 1910.1200(a)(2) for examples and the requirement to develop and maintain a written program.

Chemical manufacturers and importers must classify the hazards of the chemicals they produce or import, and all employers must provide information to their employees about hazardous chemicals they are exposed to. This obligation is described in 1910.1200(b)(1).

The standard applies to any chemical that is known to be present in the workplace in a way employees may be exposed during normal use or in a foreseeable emergency. See 1910.1200(b)(2) for the scope and application.

No — laboratory employers must ensure labels on incoming containers of hazardous chemicals are not removed or defaced. That duty is explicitly stated in 1910.1200(b)(3)(i).

Yes — laboratory employers must maintain any safety data sheets received with incoming shipments and ensure they are readily accessible during each workshift to laboratory employees when they are in their work areas, as required by 1910.1200(b)(3)(ii).

Laboratory employees must be provided information and training in accordance with paragraph (h), except they do not need training on the location and availability of the written hazard communication program. See 1910.1200(b)(3)(iii) and the training requirements at 1910.1200(h).

A laboratory that ships hazardous chemicals is treated as a chemical manufacturer or distributor and must ensure containers leaving the lab are labeled per the workplace/shipping labeling rules and that an SDS is provided to distributors and other employers as required. See 1910.1200(b)(3)(iv), and the labeling and SDS obligations in 1910.1200(f) and 1910.1200(g)(6) / 1910.1200(g)(7).

Employers must keep incoming container labels intact, retain and provide SDSs for sealed-container shipments (obtain one as soon as possible if missing upon employee request), and provide information and training needed to protect employees in case of a spill or leak. See 1910.1200(b)(4)(i)-(iii).

Certain chemicals already regulated by other federal labeling laws are excluded from this labeling requirement — for example, pesticides covered by FIFRA, chemicals subject to Toxic Substances Control Act (TSCA) labeling, and many foods/drugs/cosmetics subject to the Federal Food, Drug, and Cosmetic Act. See the exclusions in 1910.1200(b)(5) and specific subparagraphs like 1910.1200(b)(5)(i) and 1910.1200(b)(5)(iii).

The standard does not apply to several categories such as hazardous wastes regulated under RCRA, tobacco products, certain untreated wood, articles, and many retail food or beverage items used or sold for consumption. See the list of exclusions in 1910.1200(b)(6) and specific examples like 1910.1200(b)(6)(i) and 1910.1200(b)(6)(v).

Wood and wood products are exempt only if the manufacturer/importer shows the only hazard they pose is flammability or combustibility; treated wood, wood that will be sawed or cut (creating dust), or wood treated with hazardous chemicals are not exempt. See 1910.1200(b)(6)(iv).

An "article" that meets the definition in paragraph (c) is excluded from the standard when its shipment or use does not expose employees to hazardous chemical hazards as defined; the precise definition appears in paragraph (c) of the standard. See the exemption listed at 1910.1200(b)(6)(v) and consult the main Hazard Communication standard at 1910.1200 for the paragraph (c) definition.

Employers and manufacturers must ensure containers leaving their control are labeled with identity and hazard information so employees and downstream users can recognize hazards; see the labeling requirements in 1910.1200(f) for specific label elements and exceptions.

Manufacturers, importers, and distributors must prepare and provide a Safety Data Sheet that contains specified hazard and protective information to employers and downstream users; see the SDS requirements in 1910.1200(g).

An SDS must be provided to distributors and other employers whenever hazardous chemicals are shipped, and suppliers must update and provide revised SDSs when new hazard information becomes available. See the duties described in 1910.1200(g)(6) and 1910.1200(g)(7).

Employers must train employees on the hazardous chemicals in their work area, how to read labels and SDSs, and protective measures (including emergency procedures). The training requirements are in 1910.1200(h).

Training must be provided at the time of an employee's initial assignment to a work area where hazardous chemicals are present and whenever a new hazard is introduced that the employee hasn't been trained on; see timing and content requirements in 1910.1200(h)(2).

Laboratory employees are not required to be trained on the location and availability of the written hazard communication program as part of the laboratory-specific exception; see 1910.1200(b)(3)(iii) and the training location requirement in 1910.1200(h)(2)(iii).

Employers must obtain a safety data sheet as soon as possible for sealed containers received without an SDS if an employee requests it, and ensure SDSs are readily accessible during each workshift, as required by 1910.1200(b)(4)(ii).

Training must include the information and procedures necessary to protect employees in case of a spill or leak from a sealed container — such as recognition of hazards, emergency procedures, and any required PPE — as stated in 1910.1200(b)(4)(iii) and the broader training content in 1910.1200(h).

Incoming container labels must not be removed or defaced, but workplace labeling requirements apply when chemicals are transferred to secondary containers for use — employers must follow the workplace labeling provisions in 1910.1200(f) while ensuring incoming labels remain intact per 1910.1200(b)(3)(i).

Yes — PSM coverage can depend on the Hazard Communication classification; if a refrigerant or gas meets the Category 1 flammable gas definition under 1910.1200 and the aggregate quantity on site in one location meets PSM thresholds, the PSM standard applies. See OSHA's interpretation on PSM flammable gas aggregation at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06 for details and how [1910.119] and [1910.1200] interact.

An "article" under 1910.1200(c) is a manufactured item that (1) is made to a specific shape or design, (2) has its end-use function dependent on that shape or design, and (3) under normal use does not release more than very small (minute or trace) amounts of a hazardous chemical or pose a physical or health risk. See 1910.1200(c).

• Practical test: ask whether the item’s function depends on its shape, whether it’s intentionally a fluid or particle, and whether normal use could release more than trace amounts of hazardous chemicals as determined under 1910.1200(d).
• Example: a steel bolt formed to a specific shape and that does not release hazardous chemicals in normal use is an "article."

Immediate use means the hazardous chemical is under the control of and used only by the person who transfers it from a labeled container and only within the same work shift in which it is transferred. See 1910.1200.

• Practical effect: if a worker takes a properly labeled container to their workstation and uses it during that shift, some labeling/SDS requirements are relaxed for that transferred portion because it qualifies as "immediate use."
• Employer action: confirm the transfer meets the time-and-control limits before treating the transferred material as "immediate use."

A consumer product is exempt under 1910.1200(b)(6)(x) if the employer can show the product is used in the workplace for the purpose intended by the manufacturer or importer and the employee exposures are not greater in duration or frequency than typical consumer use. See 1910.1200(b)(6)(x).

• Practical implication: common household cleaners used exactly as the label directs and with exposures similar to consumer settings may be treated as exempt, but if you use them in industrial quantities or for a different purpose, the exemption likely does not apply.
• Employer action: document intended use and expected exposures if claiming the consumer-product exemption.

Nuisance particulates are excluded from coverage only when the chemical manufacturer or importer can establish they do not pose any physical hazard, health hazard, or other hazards covered under 1910.1200. See 1910.1200(b)(6)(xi).

• Practical tip: if a powder truly has no health or physical hazards, SDS and labeling may not be required; however, manufacturers/importers must have the basis for that determination.
• Employer action: verify hazard information from the supplier/manufacturer and retain documentation showing the particulate meets the exclusion criteria before treating it as not hazardous.

Biological hazards are explicitly listed in 1910.1200(b)(6)(xii) and therefore are not excluded from the standard's coverage by that paragraph. See 1910.1200(b)(6)(xii).

• Practical implication: hazards from biological agents (e.g., certain infectious materials) are considered when determining hazard communication obligations; however, other OSHA or CDC standards may also apply.
• Employer action: treat known biological hazards as hazardous chemicals for hazard communication purposes and provide appropriate labeling, SDSs, and training unless another regulation provides alternate controls.

You determine whether an article releases more than "very small quantities" by evaluating the likely release during normal conditions of use and comparing it to the "minute or trace" threshold described in paragraph (d) of 1910.1200. See 1910.1200(d).

• Practical steps: review manufacturer data, exposure assessments, and the guidance in paragraph (d) to decide if normal use results in only trace releases; if releases could be larger, the item is not an "article" and must be treated as a hazardous chemical.
• Employer action: document your determination and, when in doubt, treat the item as a hazardous chemical to ensure worker protection.

A hazardous chemical under 1910.1200 is any chemical classified as posing a physical hazard or a health hazard, or as a simple asphyxiant, combustible dust, or hazard not otherwise classified (HNOC). See 1910.1200.

• Health hazards include acute toxicity, skin corrosion/irritation, eye damage/irritation, respiratory or skin sensitization, germ cell mutagenicity, carcinogenicity, reproductive toxicity, target organ toxicity, and aspiration hazard (see the definitions in the standard).
• Employer action: identify hazardous chemicals in the workplace and follow classification, labeling, SDS, and training requirements in 1910.1200.

Mixtures must be classified by reviewing the available data for the mixture and its components to identify any physical or health hazards and, where appropriate, determining the degree of hazard by comparing data to the criteria in the standard. See 1910.1200(c).

• Use the criteria in Appendix A for health hazards and Appendix B for physical hazards to assign hazard classes and categories.
• Employer action: document the classification process and ensure labels and SDSs reflect the hazards identified for the mixture and its components.

Appendix A contains the criteria for determining whether a chemical is a health hazard and Appendix B contains the criteria for determining whether a chemical is a physical hazard; both are the official criteria you must use when classifying chemicals under 1910.1200. See 1910.1200 Appendix A and 1910.1200 Appendix B.

• Practical consequence: classification is not based on guesswork—compare your hazard data to the criteria in those appendices to determine hazard class and category.
• Employer action: retain documentation of how data compare to the appendix criteria in case of inspections or employee questions.

A label must include required label elements such as the product identifier, pictograms, signal word, hazard statements, and precautionary statements as specified by the standard; the product identifier is the name or number used for a hazardous chemical on a label or in the SDS so users can identify the chemical. See 1910.1200 and the definition of product identifier in 1910.1200.

• Practical tip: the product identifier on the container label must match the product identifier used on the SDS so employees can cross-reference them.
• Employer action: ensure every hazardous chemical container has a label with the required elements and that SDS product identifiers match container labels.

A pictogram under 1910.1200 is a composition that may include a symbol plus other graphic elements intended to convey specific hazard information, and eight pictograms are designated under the standard for application to hazard categories. See 1910.1200 and the definition for pictogram.

• Practical use: pictograms are the red-diamond symbols placed on labels to quickly show the primary hazards (for example flame for flammables, skull and crossbones for acute toxicity).
• Employer action: apply the correct pictogram for each hazard class and category identified during classification.

Chemical manufacturers and importers are responsible for classifying hazardous chemicals and for developing and providing labels and Safety Data Sheets (SDSs); distributors must ensure labels and SDSs are transmitted, and employers must maintain SDSs and labels in the workplace. See 1910.1200.

• Practical steps for employers: verify the supplier provides an SDS and that container labels are intact when materials arrive; maintain accessible SDSs and train employees on chemical hazards.
• Employer action: if a manufacturer/importer has not provided classification information, employers must still protect their employees and may need to classify the chemical or obtain the information.

No—1910.1200 specifically excludes pipes or piping systems, engines, fuel tanks, and other operating systems in a vehicle from the definition of "container." See 1910.1200.

• Practical implication: although piping is not a "container," employers should still ensure employees know what chemicals are present in process piping and have access to appropriate hazard information and emergency procedures.
• Employer action: use process piping identification systems and accessible SDSs to communicate hazards for chemicals in pipes.

Exposure or "exposed" means that an employee is subjected in the course of employment to a hazardous chemical and includes potential exposure (e.g., accidental or possible exposure); routes of entry include inhalation, ingestion, skin contact, or absorption. See 1910.1200 and the definition of "exposure or exposed."

• Practical consequence: employers must assess and control all plausible exposure routes and provide appropriate PPE and training.
• Employer action: include inhalation and dermal controls in hazard assessments and ensure SDSs and labels address relevant exposure routes.

A foreseeable emergency is any potential occurrence such as equipment failure, rupture of containers, or failure of control equipment that could result in an uncontrolled release of a hazardous chemical into the workplace; it matters because employers must plan for such events in hazard communication and emergency response. See 1910.1200.

• Practical actions: include foreseeable emergency scenarios in your SDS review, labeling, employee training, and spill-response procedures.
• Employer action: ensure employees know emergency procedures and have access to SDSs and appropriate PPE for foreseeable emergencies.

A hazard class describes the nature of the physical or health hazard (for example, flammable liquid or carcinogen), while a hazard category divides that hazard class into levels of severity (for example, flammable liquids have categories 1–4). See 1910.1200.

• Practical use: classification assigns a hazard class and then, if applicable, a hazard category to show the degree of hazard—labels and SDSs reflect both.
• Employer action: treat higher-category hazards with stricter controls and ensure training emphasizes the severity differences among categories.

Combustible dust is defined as finely divided solid particulates of a substance or mixture that pose a flash-fire or explosion hazard when dispersed in air or other oxidizing media, and employers must identify and control combustible dust hazards under the standard. See 1910.1200.

• Practical implication: materials not typically considered flammable in bulk can create severe explosion risks as dusts; hazard communication, housekeeping, ignition-source control, and dust-control measures are critical.
• Employer action: evaluate processes for dust generation, apply appropriate engineering controls, and ensure SDSs and labels reflect combustible-dust hazards.

An employer can treat a consumer product like hand sanitizer as exempt only if it is used in the workplace for the purpose intended by the manufacturer/importer and the duration and frequency of exposure are not greater than what consumers would experience, per 1910.1200(b)(6)(x). See 1910.1200(b)(6)(x).

• Practical consideration: frequent industrial-scale use, dispensing in bulk, or uses not intended by the manufacturer will likely remove the exemption and require SDSs/labels and training.
• Employer action: document intended use and exposure patterns if relying on the consumer-product exemption; otherwise maintain SDSs and labels and provide training.

Category 1 flammable gases are gases that at 20°C and standard pressure are ignitable in air at 13% volume or less or have a flammable range of at least 12 percentage points; identifying a gas as Category 1 under 1910.1200 can make it a highly hazardous chemical for other standards such as Process Safety Management (PSM). See 1910.1200 Appendix B and OSHA's letter of interpretation on PSM flammable gas aggregation (Original URL: https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06).

• Practical consequence: if you have Category 1 flammable gas on site above certain quantities, other standards (for example, 29 CFR 1910.119 PSM) may apply; OSHA applied this reasoning in its PSM flammable gas aggregation interpretation.
• Employer action: determine flammability category during classification, then check thresholds for any other OSHA standards that may apply and document your determinations.

If a supplier does not provide an SDS or adequate hazard information, the employer must take steps to obtain the information from the supplier or classify the chemical themselves and ensure employees still receive hazard information and training as required by 1910.1200. See 1910.1200.

• Practical steps: contact the supplier in writing, request an SDS, document contacts, and if necessary conduct a hazard assessment and create workplace labels and training materials so employees are protected.
• Employer action: keep records of attempts to obtain supplier information and any workplace classification steps taken.

Labels on shipped containers must include the product identifier, signal word, hazard statement(s), pictogram(s), precautionary statement(s), and the name/address/telephone of the manufacturer, importer, or other responsible party. See 1910.1200(f)(1) for the list of required elements and 1910.1200(f)(2) for formatting and language requirements.

• The specific elements are enumerated at 1910.1200(f)(1)(i)–(vi).
• The content and layout for signal words, hazard statements, pictograms, and precautionary statements should be consistent with Appendix C to 1910.1200.

Practical tip: Make sure label text matches the corresponding Safety Data Sheet (SDS) and that the label information is prominently displayed and in English (you may include other languages if appropriate) as required by 1910.1200(f)(2).

Employers must keep a written list of hazardous chemicals known to be present that uses a product identifier matching the one on the appropriate SDS; the list can be for the whole workplace or for individual work areas. See 1910.1200(e)(1) and 1910.1200(e)(1)(i).

• Use the same product identifier on the list that appears on the SDS and the container label so employees and responders can cross-reference information easily.
• You may organize the list by the entire facility or by individual work areas—choose whichever format helps employees locate hazards quickly.

Practical tip: Update the list whenever you receive a new SDS or when chemicals are introduced or removed so the written hazard communication program stays accurate (this supports label/SDS cross-referencing required under 1910.1200(f)(1)(i)).

The employer must describe in the written hazard communication program the methods it will use to inform employees about the hazards of non-routine tasks and chemicals in unlabeled pipes. See 1910.1200(e)(1)(ii).

• Common methods to meet this requirement include written procedures, pre-job briefings, specific training before the task, clear signage or tagging of pipes, and ready access to SDSs for the chemicals involved.
• For unlabeled pipes, identify the chemical by product identifier and ensure employees know the hazards and required precautions before they work on or near the pipe.

Practical tip: Put the method in writing (for example: "non-routine tasks will receive a task-specific briefing and the SDS will be reviewed on-site") and include it in your written program so you can show compliance with 1910.1200(e)(1).

At multi-employer workplaces, employers must ensure their hazard communication program includes methods to give on-site access to SDSs, inform other employers about precautionary measures and foreseeable emergencies, and explain the workplace labeling system. See 1910.1200(e)(2) and its subparts 1910.1200(e)(2)(i)–(iii).

• Provide on-site access to SDSs for each hazardous chemical other employers' employees may be exposed to (1910.1200(e)(2)(i)).
• Inform other employers of any precautionary measures (PPE, engineering controls, work practices) needed during normal operations and foreseeable emergencies (1910.1200(e)(2)(ii)).
• Explain the labeling system used on-site so outside employees can recognize hazards quickly (1910.1200(e)(2)(iii)).

Practical tip: Host employers often meet these duties by keeping a binder or electronic file of SDSs at the site, conducting an orientation with contractor supervisors, and providing a simple one-page summary of on-site labels and required precautions.

For certain solid materials (like a solid metal item, solid wood, or plastic item that is not an exempted article), the required label may be transmitted to the customer at the time of the initial shipment and need not appear on subsequent shipments to the same employer unless the label information changes. See 1910.1200(f)(4)(i)–(iii).

• The exception applies only to the solid material itself (e.g., a steel beam) and not to hazardous chemicals used with or present on the material (for example, cutting fluids or pesticides) — those still require labeling on each container if employees handling the items may be exposed (1910.1200(f)(4)(iii)).
• The label may be sent with the initial shipment or with the SDS provided prior to or at the time of the first shipment (1910.1200(f)(4)(ii)).

Practical tip: If you’re a supplier relying on this exception, keep records showing the initial label/SDS was provided and monitor for changes that would trigger re-labeling for later shipments as required by 1910.1200(f)(4).

Yes — chemical manufacturers and importers of mixtures may rely on the information provided on the current SDSs of the individual ingredients when classifying mixtures, except when they know, or with reasonable diligence should know, that an SDS misstates or omits information required by the standard. See 1910.1200(d)(3)(ii).

• Manufacturers must follow the procedures in Appendices A and B to 1910.1200 when classifying hazards and determining coverage for mixtures (1910.1200(d)(3)(i)).
• There is no requirement to test the chemical if adequate scientific literature and other evidence are available, but manufacturers and importers must consider the full range of available information when classifying hazards (1910.1200(d)(2)).

Practical tip: If you rely on ingredient SDSs, document your diligence (e.g., review dates, data sources) and correct any misstatements or omissions promptly to remain compliant with 1910.1200(d).

The employer must make the written hazard communication program available, upon request, to employees, their designated representatives, the Assistant Secretary, and the Director, in accordance with the access and disclosure rules at 1910.1020(e). See 1910.1200(e)(4) and 1910.1020(e).

• Requests for the program by employees or their representatives must be honored and the program provided in a timely manner consistent with the record-access procedures in 1910.1020(e).
• If employees travel between multiple work locations during a shift, the written program may be kept at the primary workplace facility (1910.1200(e)(5)).

Practical tip: Keep a readily retrievable copy (paper or electronic) and document requests and responses so you can demonstrate compliance with 1910.1200(e)(4) and the access rules in 1910.1020(e).