What Is a Hazard Communication Program and Do I Need One?

A Hazard Communication (HazCom) program is OSHA's requirement that employers inform their workers about the hazardous chemicals they work with — in writing, with labeled containers, accessible Safety Data Sheets, and documented training. It is the #2 most cited OSHA standard nationally (FY 2025) and applies to virtually every Texas business that has any chemicals on site.

The Six Required Elements of a HazCom Program

29 CFR 1910.1200(e) lists the required contents of a written HazCom program. All six must be present:

1. Written Program Statement

A document describing how your workplace manages chemical hazards — who is responsible, how the program is maintained, and how it applies to contractor workers on your site. This is the document OSHA asks for first. It must reference 29 CFR 1910.1200(e) explicitly.

2. Chemical Inventory

A list of every hazardous chemical present in your workplace. For each chemical, the inventory should include the product name, the hazard class, the SDS status, and the primary storage location. "Cleaning closet" is not sufficient — name the specific location. This list must be kept current as chemicals change.

3. Safety Data Sheet (SDS) Management

An SDS must be available for every chemical on your inventory. SDSs must be in GHS format (16 sections) and must be immediately accessible to workers during their shift — not locked in a manager's office. The written program must state the specific location of the SDS binder or electronic system.

4. Container Labeling

Every hazardous chemical container must have a GHS-compliant label with six elements: product identifier, signal word (Danger or Warning), hazard statement, precautionary statement, pictograms, and supplier contact information. This applies to secondary containers — if you transfer a chemical into a spray bottle, that bottle needs a label too.

5. Employee Training

Workers must be trained on the HazCom standard before they work with hazardous chemicals and when new chemicals are introduced. Training must cover how to read SDSs, what the GHS pictograms mean, and the specific chemicals in their work area. Training must be documented with employee names, dates, and topics covered.

6. Contractor Coordination

If contractors work in your facility and may be exposed to your chemicals, you must inform them of the hazards and make SDSs available. If their chemicals could expose your workers, they must provide you with SDSs for their chemicals.

GHS — What It Means and Why It Matters

GHS stands for the Globally Harmonized System of Classification and Labelling of Chemicals. OSHA adopted the GHS in 2012, aligning the HazCom standard with international chemical safety practice. GHS standardized the SDS format (16 sections) and the label pictograms. An older MSDS (Material Safety Data Sheet) is not the same as a GHS SDS — if your binders still have the old 9-section MSDS format, they are out of compliance.

Industry-Specific Hazards That Require Special Attention

Salons and Cosmetology

Formaldehyde in keratin smoothing treatments triggers OSHA's formaldehyde standard (1910.1048) in addition to HazCom. If airborne formaldehyde levels exceed the action level (0.1 ppm 8-hr TWA), air monitoring and medical surveillance may be required. At minimum, the HazCom program must address formaldehyde explicitly, and SDSs for keratin products must be reviewed for formaldehyde content.

Food and Beverage

The never-mix rule must be documented: bleach (sodium hypochlorite) and ammonia-based cleaners produce chloramine gas when mixed — a serious inhalation hazard. Your HazCom program must identify incompatible chemicals and document segregation requirements. DSHS food handler certification does not substitute for HazCom compliance.

Auto Services

Refrigerants (EPA 608 certification is separate but related), used oil, brake fluid with asbestos risk in pre-2001 vehicles, solvents, and battery acid all require SDS documentation. The chemical inventory in an auto shop is typically one of the longer ones — thoroughness matters.

Lawn and Landscape

Pesticides are hazardous chemicals under HazCom. The TDA (Texas Department of Agriculture) pesticide applicator license is a state requirement; HazCom is the federal overlay. SDSs for every pesticide product in use must be current and accessible to crew members — including those who do not directly apply pesticides but may be exposed to application areas.

What Happens If You Don't Have a Written HazCom Program

HazCom is the #2 most cited standard nationally. It is cited in serious, other-than-serious, and willful categories depending on the circumstances. A missing written program is typically cited as a serious violation — up to $16,550 per violation (2026). Multiple elements can be cited separately: missing written program, missing SDS, unlabeled container, no training records — each is a potential citation.

What ReadyDocs Safe Provides

The HazCom Program in every ReadyDocs Safe product is built for your specific industry with a pre-populated chemical inventory framework, industry-specific hazard language, GHS labeling requirements, SDS management procedures, and employee training documentation. Available as part of the Starter Pack ($297), Complete Safety System ($597), or as a standalone add-on.