Safety

Hazard Communication Program Template

Hazard communication was the second most cited federal OSHA standard in fiscal year 2024, and the written program is the document that ties labels, safety data sheets and training together. If your crews use form oil, fuel, solvents, sealants or cement, you need one. This is it, with the chemical inventory built in.

What a written HazCom program has to contain

Construction’s rule, 1926.59, adopts 1910.1200 word for word. Paragraph (e) asks for a program at each workplace that at least describes how labels, safety data sheets and training will be handled, plus:

ParagraphRequired content
(e)(1)How labels, SDSs and training will be handled — described, not just promised
(e)(1)(i)A list of hazardous chemicals known to be present, by the product identifier on each SDS
(e)(1)(ii)How employees are told about non-routine tasks and chemicals in unlabelled pipes
(e)(2)On a multi-employer site: SDS access for the other employers, precautions, your labelling system
(e)(4)Available on request to employees, their representatives, OSHA and NIOSH

Read from 29 CFR 1910.1200(e) on 2026-10-18.

How to fill it in

  1. Walk the gang boxes and the trailer. Every product goes on the inventory under the identifier printed on its safety data sheet. The tool counts the sheets you still need.
  2. Write the label rule for secondary containers. Workplace labels may be the full shipped-container label, or the product identifier plus words, pictures or symbols giving at least general information on the hazards.
  3. Say where the SDSs are and how a crew reaches them on this shift. Readily accessible means on site, not at head office.
  4. Set the training trigger. At initial assignment and whenever a new chemical hazard is introduced into the work area. Log it on the training matrix.
  5. Fill in the multi-employer exchange. Construction is the example the rule itself uses: employees of a contractor working on someone else’s site.

Caution

Two common silent failures: a product bought on the way to site that never made the inventory, and a spray bottle with no label. The first breaks the inventory in (e)(1)(i); the second breaks the workplace labelling rule in (f)(6).

What the training must cover

Under (h)(3), at least: how to detect the presence or release of a hazardous chemical; the physical, health, simple asphyxiation, combustible dust and pyrophoric gas hazards of the chemicals in the work area; the protective measures, including work practices, emergency procedures and PPE; and the details of your program, including how to read labels and SDSs. Silica has its own extra duty: it must be in this program, with cancer, lung, immune system and kidney effects addressed (silica standard).

The 2026 deadline

The current rule took effect July 19, 2024. For substances, employers must update alternative workplace labelling, the program and training as necessary by November 20, 2026; for mixtures, by May 19, 2028 ((j)). In practice: when a supplier sends a revised SDS with a new classification, change the label rule, the inventory and the training to match. Put the program’s location in your site-specific safety plan.

The rule text

Quoted from the current eCFR text of title 29, read on 2026-10-18; “…” marks text left out.

Employers shall develop, implement, and maintain at each workplace, a written hazard communication program which at least describes how the criteria specified in paragraphs (f), (g), and (h) of this section for labels and other forms of warning, safety data sheets, and employee information and training will be met, and which also includes the following: (i) A list of the hazardous chemicals known to be present using a product identifier that is referenced on the appropriate safety data sheet …

Employers who produce, use, or store hazardous chemicals at a workplace in such a way that the employees of other employer(s) may be exposed (for example, employees of a construction contractor working on-site) shall additionally ensure that the hazard communication programs developed and implemented under this paragraph (e) include the following: …

Employers shall provide employees with effective information and training on hazardous chemicals in their work area at the time of their initial assignment, and whenever a new chemical hazard the employees have not previously been trained about is introduced into their work area.

Sources, with the date each was read