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Establishing a Hazard Communication Program in the Workplace


The OSHA Hazard Communication Standard

CFR 29 1910.1200 outlines specific requirements for employers whose employees "use" hazardous chemicals in the workplace. This Standard is also known as the "right-to-know" law.

The HCS is a general document addressing requirements of manufacturers, importers, and distributors of chemicals, as well as employers whose employees use hazardous chemicals in the workplace. This document outlines the requirements for employers; additional information is available for others in the Standard.


The two main requirements of the standard for employers are:

  • Employers must ensure that employees are aware of their right to know about the hazards of the chemicals that they may be exposed to during use or during "foreseeable emergencies".
  • Employers must establish and implement a written Hazard Communication Program, and identify a specific person or persons responsible, as well as specific procedures, for the oversight of the chem inventory, MSDS, training, and evaluation.

What employers are required to do: chemical inventory, labels, MSDS, training and evaluation

The HCS specifies that at least one person must be responsible for ensuring compliance to the HCS, and this person must be idetified and the responsibilities must be an explicit part of job responsibilities. All hazardous chemicals to which employees may be exposed must be identified and inventoried. MSDS must be acquired and files maintained and made readily accessible to employees. Ensure proper labeling on containers. Ensure proper training in language of job training. Ensure employee understanding. All procedures must be spelled out for each of these responsibilities in a written Hazardous Communication Program.

The employer does have the responsibility of evaluating employee understanding of training, even if the training was received at a previous job. This training must involve the following:

  • Training on the "right-to-know" and the details ofemployer requirements for labeling, MSDS availability, and requirements of the written Hazardous Communication Program
  • Both physical and health hazards foreseeably exposed to, including target organs, bodily changes and signs and symptoms.