A hazard communication program takes more than just safety data sheets and labels. Here are the gaps that cause citations and how to close them.

A worker picks up an unmarked spray bottle at the start of a shift. The safety data sheet binder sits in an office on the other side of the site, and the label on the nearest drum has worn away.

The company has all the paperwork, yet the worker cannot tell what the product does to skin or lungs. That gap between having information and being able to use it is exactly what a hazard communication program is meant to close.

A hazard communication program is the written plan an employer keeps to show how workers will learn about the chemicals they handle through labels, safety data sheets (SDS) and training.

OSHA's Hazard Communication standard, 29 CFR 1910.1200, sets the requirements for any workplace with hazardous chemicals. That covers everything from a chemical plant to an auto repair shop.

Most failures happen in the gaps between the required parts of the program: the chemical list, access to sheets, label reading, training and upkeep. This article walks through those gaps and how to close them.

OSHA requires a written plan at each workplace that has hazardous chemicals, under 29 CFR 1910.1200. Your program is a record of how your workplace handles chemical information, not a copy of the standard.

The written program describes:

• The list of hazardous chemicals on site, by the product name used on each sheet.
• How containers are labeled.
• Where sheets are kept and how workers reach them.
• How and when workers are trained.
• How workers learn about unusual tasks and unmarked pipes.
• How contractors and other employers on the same site get the same information.

Without the chemical list, no one can say which sheets should be on file.

Many programs fall short because they are out of date or leave people out. OSHA citation data shows where problems turn up:

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