Hazard Communication (29 CFR 1910.1200)
The Hazard Communication Standard (HazCom) requires employers to inform workers about chemical hazards through labels, Safety Data Sheets (SDS), and training. It applies to every construction site where chemicals are present.
What 29 CFR 1910.1200 Requires
The Hazard Communication Standard applies to every workplace where employees may be exposed to hazardous chemicals. On construction sites, this means paints, solvents, adhesives, concrete additives, cleaning agents, and dozens of other common materials all trigger HazCom obligations. Here is what the standard requires:
- Written hazard communication program identifying chemical hazards on site
- Safety Data Sheets (SDS) for every hazardous chemical, accessible to all employees
- Container labeling with product identifier, hazard pictograms, and supplier info
- Employee training on chemical hazards before initial exposure and when new hazards are introduced
- List of all hazardous chemicals present in the workplace
- Multi-employer worksite coordination for shared chemical hazard information
Most Common Violations
HazCom violations are among the most frequently cited because the standard applies across all industries, not just construction. Many contractors assume chemical hazard documentation is only relevant to manufacturing or lab settings — but inspectors evaluate it on every jobsite where chemicals are present:
- No written hazard communication program
- Missing or inaccessible Safety Data Sheets
- Unlabeled or improperly labeled chemical containers
- No employee training documentation on chemical hazards
- Failure to update chemical inventory when new products are introduced
- Secondary containers without proper labeling
Penalty Exposure
Penalty range: $1,190–$16,550 per serious violation; up to $165,514 per willful violation
A missing written HazCom program is a single citation that can carry a penalty up to $16,550 in 2026. But HazCom violations often come in groups — a missing program, unlabeled containers, inaccessible SDS binders, and no training records can each be cited separately. A single inspection can easily produce four or five HazCom citations totaling $50,000 or more.
The documentation distinction matters here more than with any other standard. Inspectors distinguish between employers who have a program with minor gaps (serious violation with reductions) and employers who have no program at all (potential willful classification at 10x the penalty). Having a written program — even an imperfect one — is the single most important factor in penalty classification.
Documentation You Need
HazCom documentation is straightforward to organize but easy to neglect. Unlike fall protection or scaffolding, the paperwork does not require specialized engineering knowledge — it requires consistency. Refer to the full OSHA documentation requirements for contractors for a broader overview. Here is what you need specifically for HazCom:
- Written HazCom program with responsible person identified
- Complete chemical inventory list with product names and manufacturers
- SDS collection — organized, current, and accessible during work hours
- Training records showing date, topics, trainer, and employee signatures
- Evidence of labeling compliance (photos or inspection records)
- Multi-employer communication records (for sites with multiple contractors)
What Inspectors Look For
During an OSHA inspection, HazCom is typically evaluated during the opening conference document review and confirmed during the walkaround. Inspectors will ask workers directly whether they know where the SDS binder is and what chemicals they work with. Here is the full checklist:
- Written HazCom program — this is typically requested during document review
- SDS binder or digital access point — can workers access it during work?
- Container labels — secondary containers are the most common failure point
- Training records with specifics on chemicals used on this site
- Chemical inventory accuracy — does the list match what is actually on site?
- Employee awareness — can workers describe the hazards of chemicals they use?
Get Your HazCom Documentation Organized
The OSHA Defense Documentation System includes a hazard communication program template, training documentation forms, and chemical inventory tracking — covering every HazCom documentation requirement inspectors evaluate.
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