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HazCom Written Program Generator

Every employer with a hazardous chemical in the workplace needs a written hazard communication program. This generator builds one around what 29 CFR 1910.1200(e)(1) actually requires: a description of how the label, safety data sheet and training criteria will be met, a list of the hazardous chemicals present by the product identifier used on the SDS, and the methods used for non-routine tasks and unlabeled pipes.

1910.1200 sets no review interval. Most employers review with the chemical list; write down whatever you actually do.
Available on request to employees, their designated representatives, the Assistant Secretary and the Director, per 1910.1020(e).

Nothing you type is sent to our servers. A draft is kept in this browser until you clear it.

Template for informational purposes only. This document must be reviewed and adapted by a competent or qualified person for your specific jobsite, equipment, and applicable federal, state, and local requirements. It does not constitute legal, engineering, or safety advice and does not by itself establish compliance with OSHA or any other standard. SteelToeTools assumes no liability for its use. Nothing you type is sent to our servers.

How to use this program

  1. 1
    Walk the site before you write anything. The chemical list is the part inspectors read first, and it is the part that goes stale fastest. Open the gang boxes, the paint locker, the fuel cage and the janitor's closet, and write down what is actually there.
  2. 2
    Copy the product identifier off the safety data sheet, not off the can. (e)(1)(i) asks for a product identifier that is referenced on the appropriate safety data sheet. Trade names on a label sometimes differ from the identifier in section 1 of the sheet; the sheet wins.
  3. 3
    Describe methods, not intentions. Paragraph (e)(1) asks how the criteria of (f), (g) and (h) will be met. “Secondary containers get a printed identifier and pictogram tag from the trailer printer” is a method. “We comply with GHS labeling” is not.
  4. 4
    Do not skip the two odd ones. Non-routine tasks and unlabeled pipes are the elements most written programs forget, and they are named explicitly in (e)(1)(ii). If you have neither, say so in the document rather than leaving the section blank.
  5. 5
    Hand it to the crew, not just to the file. Under (h)(2)(iii), employees have to be told where this program, the list and the sheets are. Run the handover as a short talk — SDS, labels and pictograms covers the same ground in ten minutes — and record attendance.

What OSHA requires

29 CFR 1910.1200(e)(1) requires employers to develop, implement and maintain at each workplace a written hazard communication program. Construction is covered as well: 29 CFR 1926.59 adopts 1910.1200 for construction work. The written program has to do three things.

What the written hazard communication program must contain — 29 CFR 1910.1200(e)(1)
What the program must containOn this form
(e)(1)A description of how the criteria in paragraphs (f), (g) and (h) — labels and other forms of warning, safety data sheets, and employee information and training — will be metSections 2, 3 and 4
(e)(1)(i)A list of the hazardous chemicals known to be present, using a product identifier that is referenced on the appropriate safety data sheet (compiled for the workplace as a whole or for individual work areas)Section 1
(e)(1)(ii)The methods the employer will use to inform employees of the hazards of non-routine tasks, and the hazards associated with chemicals contained in unlabeled pipes in their work areasSection 5
(e)(2)(i)-(iii)On multi-employer workplaces: the methods used to give other employers on-site access to safety data sheets, to inform them of precautionary measures, and to inform them of the labeling system usedSection 6

Three more obligations sit around the document. (e)(3): an employer may rely on an existing program, provided it meets the criteria of paragraph (e). (e)(4): the written program must be made available on request to employees, their designated representatives, the Assistant Secretary and the Director, in accordance with 29 CFR 1910.1020(e). (e)(5): where employees travel between workplaces during a shift, the program may be kept at the primary workplace facility.

The three criteria the program describes

  • Labels — (f). Shipped containers carry the product identifier, signal word, hazard statements, pictograms, precautionary statements and supplier contact information ((f)(1)). Workplace containers carry either that same information or a product identifier plus words, pictures or symbols giving at least general hazard information ((f)(6)). Signs and batch tickets may stand in for labels on stationary process containers ((f)(7)), and a portable container used immediately by the person who filled it needs no label ((f)(8)).
  • Safety data sheets — (g). Copies are maintained and readily accessible during each work shift to employees in their work areas; electronic access is permitted as long as it creates no barrier to immediate access ((g)(8)).
  • Information and training — (h). Provided at initial assignment and whenever a new chemical hazard is introduced ((h)(1)); employees are informed of the three items in (h)(2) and trained on the four items in (h)(3), including how to read a safety data sheet.

This generator produces a template. The employer remains responsible for the accuracy of the chemical list, for the methods described, and for actually implementing the program. Related written programs are covered in which OSHA written programs your site actually needs.

Frequently asked questions

Any employer whose employees may be exposed to a hazardous chemical under normal conditions of use or in a foreseeable emergency. 1910.1200(e)(1) requires the employer to develop, implement and maintain a written program at each workplace. Construction is covered too: 29 CFR 1926.59 adopts 1910.1200 for construction work. The written program is not optional for small employers and there is no minimum number of chemicals.

1910.1200(e)(1) asks for a document that at least describes how the criteria in paragraphs (f), (g) and (h) — labels and other forms of warning, safety data sheets, and employee information and training — will be met, and that also includes two things: a list of the hazardous chemicals known to be present, using a product identifier that is referenced on the appropriate safety data sheet, and the methods the employer will use to inform employees of the hazards of non-routine tasks and of the hazards of chemicals contained in unlabeled pipes in their work areas.

Either way. 1910.1200(e)(1)(i) says the list may be compiled for the workplace as a whole or for individual work areas. What matters is the product identifier: it has to be the one referenced on the appropriate safety data sheet, so that anyone holding the list can find the matching SDS.

No. 1910.1200(g)(8) requires the employer to maintain copies of the required safety data sheets and ensure they are readily accessible during each work shift to employees when they are in their work areas, and it states outright that electronic access and other alternatives to paper are permitted as long as no barriers to immediate employee access are created. A tablet with no signal in the basement is a barrier. Under (g)(9), employees working at more than one location may have the sheets kept at the primary workplace, provided they can immediately obtain the information in an emergency.

Not if it is for the immediate use of the person who did the pouring. 1910.1200(f)(8) exempts portable containers into which hazardous chemicals are transferred from labeled containers and which are intended only for the immediate use of the employee who performs the transfer. Set that container down for the next shift and the exemption is gone: (f)(6) applies, and the container needs either the shipped-label information or the product identifier plus words, pictures or symbols conveying the hazards.

1910.1200(h)(1): at the time of initial assignment, and whenever a new chemical hazard the employees have not previously been trained about is introduced into their work area. Training may be organized by category of hazard — flammability, carcinogenicity — rather than chemical by chemical, but chemical-specific information must always remain available through labels and safety data sheets.

1910.1200(e)(2) applies where you produce, use or store hazardous chemicals in a way that another employer's people may be exposed — the ordinary case on a construction site. The written program must then describe three methods: how you will give the other employers on site access to the safety data sheets for each chemical their employees may be exposed to, how you will inform them of precautionary measures needed during normal operating conditions and in foreseeable emergencies, and how you will inform them of the labeling system used in the workplace.

1910.1200(e)(4): the employer shall make the written program available, upon request, to employees, their designated representatives, the Assistant Secretary and the Director, in accordance with 29 CFR 1910.1020(e). In practice, an inspector asking for your HazCom program is asking for this document, the chemical list attached to it, and the sheets it points to.

Sources & references

Content checked against these sources — last reviewed August 28, 2026.

By — Editorial team of SteelToeTools.com (published by LSEA SAS) Updated v1