If your workplace stores, uses, transfers, mixes, or ships chemicals, OSHA’s Hazard Communication Standard (HazCom (29 CFR 1910.1200)) isn’t optional. And in practice, the citations don’t usually come from obscure chemistry. They come from the basics not being maintained: a written program that doesn’t match the site anymore, SDS that exist but aren’t accessible, secondary containers that are unmarked, and training that happened once.
This guide is designed to be a practical HazCom (GHS) compliance checklist you can run internally to reduce risk and prepare for OSHA scrutiny. You’ll get a clear walkthrough of what OSHA expects around labeling, SDS, training, and program documentation, plus the most common HazCom violations that trigger citations.
If you want AOTC to review your HazCom program, strengthen documentation, and resolve the issues that most often lead to OSHA citations, explore our Hazard Communication (GHS) training and compliance services.
Table of Contents
Quick HazCom refresher
HazCom is based on a straightforward principle: employees have a right to know what chemical hazards exist in their work environment, what those hazards mean, and how to protect themselves. OSHA expects this to be communicated in a way that is consistent, repeatable, and usable during normal operations, not just during an inspection.
In most workplaces, HazCom compliance rises or falls on five connected parts: a written hazard communication program, a current chemical inventory, complete and accessible Safety Data Sheets, correct GHS-aligned labeling (including secondary containers), and training that is both job-specific and documented. If one part is missing, it usually weakens the whole system. For example, training is hard to defend if the inventory is incomplete, and labels become less meaningful if SDS access is unreliable.
HazCom (GHS) compliance checklist
Think of this as a “walk the site” checklist. You’re verifying that the program exists on paper, but more importantly, you’re confirming the way chemicals are handled day-to-day matches what the documentation claims.
1) Written Hazard Communication Program (required)
Start with the written HazCom program, because it’s the document OSHA uses to measure whether your site has a system or just scattered habits. A compliant program isn’t only a binder on a shelf. It should explain, in plain operational terms, how your facility maintains its chemical inventory, how SDS are collected and made accessible, what labeling rules are used (especially for secondary containers), and how training is delivered and refreshed. It also needs to account for real-world situations that regularly create exposure risk, like non-routine tasks (tank cleaning, line breaks, equipment maintenance), and the way chemical hazards are communicated between your team and contractors.
A very common issue is that the written program is “technically present,” but it’s generic, outdated, or copied from another facility. If the program says one system is used for labeling or SDS access, but your employees rely on something else in practice, that mismatch is where OSHA tends to press.
2) Chemical inventory list
Next, confirm you have a chemical inventory that reflects what’s actually on site today. This is more than a list of bulk products used in production. It should capture chemicals in every department, including maintenance areas, janitorial closets, satellite storage rooms, and anywhere employees keep “convenience” products like aerosols, adhesives, solvents, lubricants, fuels, paints, or welding gases. The fastest way to test your inventory is to spot-check physical storage locations and compare what you find to what’s listed.
Inventory problems usually happen during change. Vendors get switched, products get substituted, new tasks get added, or a supervisor brings in “just one bottle” of something to solve an operational issue. If those changes aren’t captured consistently, the inventory drifts away from reality, and then SDS, labels, and training tend to drift with it.
3) Safety Data Sheets (SDS) management
SDS compliance is not only about having the sheets. OSHA cares that SDSs are complete, current, and readily accessible to employees during their work and not locked away or only available through a manager. “Readily accessible” also means available across all shifts. A system that works at 9 a.m. but fails at 2 a.m. is still a compliance problem.
When you review SDS, focus on two questions: do you have an SDS for every chemical on the inventory, and can an employee realistically retrieve the right SDS quickly? Many sites are confident they have SDS, but inspection prep reveals missing sheets, older versions, or a digital system employees can’t access on the floor. Another practical gap is organization; if SDS are stored in a way that makes them hard to find under pressure, employees won’t use them in real situations, and that’s exactly the kind of breakdown HazCom is meant to prevent.
A simple best practice is to define a consistent onboarding process for new chemicals: before a product enters use, the SDS is obtained, reviewed, and added to the SDS system. That one habit prevents a large portion of SDS-related citations.
4) GHS label compliance
Labeling is where HazCom becomes visible. Primary containers shipped from manufacturers should already include the required GHS elements: a product identifier, signal word, hazard statements, precautionary statements, pictograms, and supplier information. Your job is to keep those labels intact and legible so employees can interpret hazards immediately.
Secondary containers are where violations spike. These are your spray bottles, transfer jugs, day-use containers, process bottles, and any container that receives chemicals from a labeled primary container. The rule of thumb is simple: if a chemical is transferred into another container and that container isn’t strictly for the immediate use of the person who filled it, it should be labeled. Secondary containers also need labels if multiple people might use them, or if they’ll be stored beyond the immediate task or shift.
You don’t have to overcomplicate secondary labeling, but you do need consistency. A workplace labeling system should make it obvious what the chemical is and what the general hazards are. The worst-case scenario is “mystery liquid” stored in an unmarked bottle or jug because that’s exactly what triggers both exposure risk and regulatory attention.
5) Employee HazCom training
Training is often the most underestimated part of HazCom because people assume “we covered that once.” OSHA expects HazCom training at initial assignment and whenever new chemical hazards are introduced. In practice, hazards change when you introduce new products, change processes, add tasks, or change how chemicals are used or stored. Training should reflect those changes, not just repeat a generic slide deck.
Strong HazCom training does two things. First, it teaches employees how your facility’s system works: where the written program is, how to access SDS, and how labeling works in the real world (including your approach to secondary containers). Second, it ties the training directly to the hazards employees face in their roles, including safe handling, PPE expectations, engineering controls, spill response expectations, and who to notify if a chemical safety issue appears.
The other half of the training is documentation. You need proof of who attended, when training occurred, what was covered, and enough detail to show it was relevant to the job and the chemical hazards present. If you can’t document it, it’s very difficult to defend during an inspection, even if the training “really did happen.”
6) The “reality test” walk-through
Once the program, inventory, SDS, labels, and training look solid on paper, do a short floor-level verification. Walk the site and look for the places HazCom breaks down: unlabeled spray bottles, transfer containers sitting on carts, containers without caps, faded labels, mixed storage that doesn’t make sense, or employees who aren’t sure where SDS live. This walk-through isn’t about catching people doing something wrong; more so, it’s about identifying where the system isn’t set up to be followed consistently.
If employees can’t access SDS quickly, can’t interpret labels, or can’t explain what to do if a chemical spills or splashes, the system needs improvement. OSHA tends to focus on these practical, “can it work during normal operations?” signals.
Common HazCom (GHS) violations OSHA cites
Most HazCom violations are patterns, not one-off mistakes. A written program gets created and then never updated as operations evolve. An SDS binder starts complete, but becomes outdated after vendor changes. Secondary container labeling starts strong but drifts as new bottles and jugs get introduced without a simple process to keep labeling consistent. Training becomes “annual,” but generic, and documentation gets lost or doesn’t show relevance to real hazards.
If you’re prioritizing fixes, the highest-impact areas are typically: secondary container labeling, SDS accessibility across all shifts, inventory accuracy, and training documentation. These are the parts most likely to produce quick compliance wins while also reducing everyday exposure risk.
Your “ready for inspection” HazCom documentation pack
If OSHA asks for HazCom documentation, you want to produce it quickly and confidently. At a minimum, you should have a current written hazard communication program, a current chemical inventory, a complete and accessible SDS system, training records that are easy to understand and defend, and a clear labeling approach that includes secondary containers. If contractors are involved on your site, documentation should also reflect how chemical hazards are communicated both ways.
If pulling that package together would take hours (or you’re unsure what’s missing until you start hunting), that’s a strong sign the program needs a structured refresh.
How AOTC helps
AOTC helps sites get HazCom compliance back into a state that can hold up during real operations and real scrutiny. That often looks like reviewing your current program against what’s happening on the floor, rebuilding or updating the written program so it matches your processes, tightening chemical inventory and SDS management, and implementing a labeling approach that employees can follow without friction. When training is part of the gap, the goal isn’t just to “check the box,” but to build training and documentation that clearly ties back to the hazards your employees actually face.
If you want AOTC to help you close HazCom gaps and reduce violation risk, learn more about our Hazard Communication (GHS) training and compliance services.