Hazard Communication (HazCom) Training: OSHA GHS Requirements (2026)

HazCom lands in OSHA’s top 10 most cited standards year after year, and the reason isn’t that employers don’t know about it. Most employers know it exists. Many have done some version of training. The problem is that the training they’ve done covers the concept without covering the chemicals their workers actually handle. That gap is what generates citations.

A generic online course that teaches workers what a pictogram looks like doesn’t satisfy 29 CFR 1910.1200 if it never mentions the chemicals in their work area. OSHA is specific about this. The standard requires site-specific training. That’s the piece most employers miss.

What the HazCom Standard Actually Requires

The Hazard Communication Standard at 29 CFR 1910.1200 applies to any employer whose workers may be exposed to hazardous chemicals. That covers manufacturing, construction, healthcare, retail, warehousing, and agriculture, among others. The standard has five core requirements:

A written hazard communication program. This is a document, not a binder of safety data sheets. It must describe how your workplace manages labels, SDSs, and training. It must be available to workers and their representatives at any time during the workshift. Inspectors ask for it first.

A chemical inventory. You need a list of every hazardous chemical in your workplace. Not just the ones people work with directly. Any chemical with a safety data sheet that workers might encounter during their shift is on the list.

Labels on all containers. Every hazardous chemical container must be labeled. Portable containers filled during a shift and used immediately may be exempt, but anything stored or transferred needs a label with the required GHS elements. Defaced labels and missing labels are both citation triggers.

Safety data sheets for every chemical. SDSs must be available to workers during their shift. That means accessible, not locked in a supervisor’s office. Physical binders work. Digital systems work if workers can actually access them. OSHA won’t tell you the format. They will cite you if a worker couldn’t get to an SDS when they needed one.

Training. The most specific and most frequently violated requirement. Workers must be trained at initial assignment and whenever a new physical or health hazard enters their work area.

Why GHS Changed Everything

Before 2012, there was no standard format for safety data sheets or chemical labels. Manufacturers used different formats, different terminology, and different hazard categories. A worker who transferred from one employer to another might encounter a completely different label system. A hazmat responder arriving at a scene might find SDSs in any number of formats.

OSHA adopted the Globally Harmonized System of Classification and Labelling of Chemicals, known as GHS, to standardize all of that. The final rule was published in 2012, with phased compliance through 2016. It aligned the U.S. system with international standards used in the European Union, Canada, Japan, and dozens of other countries.

The practical result: every SDS now follows the same 16-section format. Every label has the same six required elements. A worker trained on GHS in the U.S. can read a chemical label from a German manufacturer and understand its hazards.

That standardization is why GHS training has a specific scope. You’re not just teaching workers about chemical hazards in general. You’re teaching them a specific system with defined terminology, specific pictograms, and a structured document format they’ll encounter on every hazardous chemical they handle.

The Six GHS Label Elements

Every GHS-compliant label must include all six of these elements. Workers need to recognize each one and understand what it communicates.

The product identifier is the chemical name or code used on the safety data sheet. It’s how you connect the label to the SDS for more detailed information.

The signal word is either “Danger” or “Warning.” Danger is the higher severity signal. Warning is used for less severe hazards. Some chemicals have no signal word if the hazard is below the threshold that triggers one.

Hazard statements are standardized phrases that describe the nature and degree of the hazard. “Causes serious eye damage” is a hazard statement. “May cause cancer” is a hazard statement. These are defined by GHS and can’t be reworded by manufacturers.

Precautionary statements describe what to do to minimize exposure or injury. “Wear protective gloves and eye protection” is a precautionary statement. “Store in a cool, dry place” is another. Labels can include prevention, response, storage, and disposal precautionary statements.

Pictograms are the nine GHS symbols, each in a red diamond border. Workers need to recognize all nine: the flame (flammable), the skull and crossbones (acute toxicity), the exclamation mark (irritants, sensitizers, less severe hazards), the health hazard (carcinogens, reproductive toxins, systemic hazards), the corrosion symbol (skin or eye damage, metal corrosion), the oxidizer (flame over circle), the gas cylinder (compressed gases), the environment symbol (aquatic toxicity), and the exploding bomb (explosives, self-reactives, organic peroxides).

Supplier information is the name, address, and phone number of the manufacturer, importer, or distributor responsible for the product.

Training workers to recognize these six elements takes about 20 minutes if done well. Most employers rush through this section and then show a video. The workers who fail label quizzes at OSHA inspections are usually the ones who got the video.

Understanding the 16-Section SDS

The standardized SDS format has 16 sections in a fixed order. Workers don’t need to memorize all 16. They need to know which sections give them the information they actually need on the job.

Section 1 covers product identifier, supplier, and emergency phone number. Section 2 is where workers go first: it lists all the hazard classifications and GHS label elements in one place. If a worker picks up an unlabeled container and needs to figure out what’s in it, Section 2 tells them whether to treat it as a serious hazard or a minor one.

Section 4, first aid measures, tells workers what to do if there’s skin contact, eye contact, ingestion, or inhalation. This should be read before someone starts working with a chemical, not after an exposure.

Section 6, accidental release, covers what to do in a spill or leak. Section 7, handling and storage, covers how to use and store the chemical safely. Section 8, exposure controls and PPE, tells workers exactly what protective equipment is required and what the permissible exposure limits are.

Section 14, transport information, becomes relevant when chemicals are being moved or shipped.

Employers must have an SDS for every hazardous chemical in the facility and keep them accessible during every shift. An SDS in a locked safety office or a binder in the back room that workers can’t reach during an emergency is a citation waiting to happen.

What Site-Specific Training Actually Means

The most common HazCom citation isn’t about missing SDSs or unlabeled containers. It’s about training that doesn’t mention the chemicals workers actually use.

OSHA’s standard at 1910.1200(h) requires training on “the specific chemicals present in their work area.” That phrase does real work in the regulation. A generic online course that covers GHS label elements and SDS sections satisfies some of the training requirement. But if it doesn’t connect those concepts to the actual chemicals a worker handles on their shift, it doesn’t fully satisfy the standard.

Compliant training for a maintenance worker who uses a specific degreaser needs to cover that degreaser. The SDS for that product. The hazards it presents. The PPE required. The emergency procedure if there’s a spill. Not a hypothetical chemical. Not a representative example. That specific product.

For employers with large chemical inventories, this creates a practical challenge. The solution most safety managers use is a two-part approach: a general GHS and HazCom overview that covers the regulatory framework, label elements, and SDS format, plus a site-specific segment that walks workers through the chemicals in their actual work area using those chemicals’ real SDSs.

Document both parts in your training records. OSHA expects to see employee names, training dates, and the content covered. If your records show workers completed the online course but nothing documents the site-specific component, you’re vulnerable.

The Written Program Requirement

The written hazard communication program is a document, not just a practice. It needs to describe three things: how your workplace manages labels (including what you do when containers come in from suppliers without proper labeling), how your workplace manages SDSs (where they’re kept, how workers access them, how new SDSs get added when new chemicals arrive), and how your training program works.

The program must list all hazardous chemicals in the workplace or reference where that list is maintained. It must be available to workers and to OSHA compliance officers on request.

Some employers treat the written program as a one-time document created during an audit and then forgotten. That’s a compliance failure waiting to surface. When new chemicals come in or processes change, the written program needs to reflect those changes. The chemical inventory is a living document.

Common Citation Patterns and Costs

HazCom has ranked in OSHA’s top 10 cited standards for over a decade. The most common patterns inspectors find:

No written program at all. More common at smaller employers who’ve done training but never formalized the documentation.

Missing SDSs for chemicals currently in use. Often happens when a new product gets purchased and no one adds the SDS to the system.

Labels that have been painted over, torn off, or made unreadable. Containers get reused. Labels get damaged. Workers aren’t responsible for relabeling. The employer is.

Training records that can’t be produced. The training may have happened, but if there’s no documentation, OSHA treats it as if it didn’t.

Training that’s generic rather than site-specific. The scenario described above: workers completed an online course but can’t name the chemicals in their work area or find the SDS for them.

For current penalty amounts, check osha.gov/penalties. OSHA adjusts penalty amounts annually, so any figure cited here will age out. OSHA fines for serious violations follow the same structure as other citations, with repeat violations carrying significantly higher penalties.

HazCom citations often appear in groups. If an inspector finds an SDS gap, they’ll usually find a label gap too. And when they pull training records, incomplete documentation of site-specific training is common. A single inspection can generate multiple HazCom citations across different subsections of the standard.

The fix isn’t complicated. A solid written program, a current chemical inventory, accessible SDSs, GHS-compliant labels on all containers, and documented training that covers both the standard and the site-specific chemicals. That’s the whole requirement.

If you’re also managing lockout/tagout as part of your chemical control program, those two programs share some documentation and training structure. Workers who understand one tend to understand the compliance logic of the other.

Key Questions

Use these answers to decide your next step quickly.

Who needs HazCom training?

Any employee who may be exposed to hazardous chemicals in the workplace needs HazCom training under 29 CFR 1910.1200. That includes production workers, maintenance staff, warehouse workers handling chemicals, and lab workers. It also includes workers who might be exposed incidentally, not just those who work directly with chemicals. OSHA interprets "hazardous chemical" broadly, so if a chemical has a safety data sheet, workers who encounter it need training.

What does HazCom training need to cover?

Training must cover: the requirements of the HazCom standard and where to find the written hazard communication program, how to read and use a safety data sheet (all 16 sections), how to read and understand GHS labels (the six required label elements: product identifier, signal word, hazard statement, precautionary statement, pictograms, and supplier information), the specific chemicals present in the employee's work area, how to detect the presence or release of hazardous chemicals, and the measures employees can take for protection.

How often does HazCom training need to be renewed?

OSHA does not set a fixed renewal interval for HazCom training. Training is required at initial assignment and whenever a new physical or health hazard is introduced into the work area. In practice, most employers provide annual HazCom refresher training because it documents ongoing compliance and keeps workers current on any chemical changes. Annual retraining is not required by OSHA but is a defensible practice.

What is an SDS and how many sections does it have?

A Safety Data Sheet (SDS) is a standardized document that provides information about the hazards of a chemical and guidance on safe handling. Under GHS, all SDSs must follow a 16-section format. The most important sections for workers are Section 2 (Hazard Identification), Section 4 (First Aid Measures), Section 6 (Accidental Release), Section 7 (Handling and Storage), Section 8 (Exposure Controls/PPE), and Section 14 (Transport Information). Employers must have an SDS for every hazardous chemical in the workplace and make them accessible to workers during their shift.

What are the most common HazCom violations OSHA cites?

HazCom is consistently in OSHA's top 10 most cited standards. The most common violations are: no written hazard communication program, missing or incomplete SDSs for chemicals in use, labels missing required GHS elements or defaced beyond recognition, no training records for workers, and training that covers the concept but not the specific chemicals present in the work area. The last one is particularly common: generic online training that doesn't mention the actual chemicals workers encounter doesn't satisfy the standard.

Need a role-based recommendation? Use the Start Here path.

---

Regulatory citations reference 29 CFR 1910.1200 (general industry) and 29 CFR 1926.59 (construction). OSHA penalty amounts adjust annually. Verify current figures at osha.gov/penalties.