Part 113 min

1.1 What HazCom is for, and who it covers

Hazard Communication was the second most frequently cited OSHA standard in fiscal year 2025, behind only fall protection. That is not because chemicals are exotic. It is because almost every workplace has them, almost every workplace is covered, and the standard asks for four things at once — a written program, labels, safety data sheets and training — so there are four ways to come up short. This chapter is about what the standard is trying to do, who it covers, and where the duties sit.

1 The idea behind the rule: a right to know

29 CFR 1910.1200 does not tell you which chemicals you may use, and it sets no exposure limits. Those live elsewhere — in 1910.1000 and 1926.55, and in the substance-specific standards. What HazCom does is move information: from the people who make and import chemicals, through the distributors, to the employer, and finally to the person holding the container.

Paragraph (b)(1) states the division of labor plainly. The section requires chemical manufacturers or importers to classify the hazards of chemicals which they produce or import; it requires all employers to provide information to their employees about the hazardous chemicals to which they are exposed, by means of a hazard communication program, labels and other forms of warning, safety data sheets, and information and training; and it requires distributors to transmit the required information to employers.

The parenthetical at the end of (b)(1) is the sentence most crews need: employers who do not produce or import chemicals need only focus on those parts of the rule that deal with establishing a workplace program and communicating information to their workers. If you buy chemicals and use them, you are not being asked to run a toxicology lab. You are being asked to keep the information flowing.

Classify — manufacturer

Transmit — distributor

Program — employer

Know — employee

2 What is covered: normal use and foreseeable emergency

The scope sentence is short and wide. Paragraph (b)(2): this section applies to any chemical which is known to be present in the workplace in such a manner that employees may be exposed under normal conditions of use or in a foreseeable emergency.

Read the two halves separately, because the second one catches most of the arguments. A drum of solvent sitting closed in a locked cage is not exposing anyone under normal conditions of use. It is very much capable of exposing people in a foreseeable emergency — a forklift tine through the side, a fire in the next bay. That is why it belongs on the list and why its safety data sheet has to be reachable.

Note also what the definitions do. A chemical is any substance, or mixture of substances. A container is any bag, barrel, bottle, box, can, cylinder, drum, reaction vessel, storage tank or the like — and the definition then says that pipes or piping systems, and engines, fuel tanks or other operating systems in a vehicle, are not containers for the purposes of this section. Pipes are not exempt from the standard; they are simply handled somewhere else, in the written program's unlabeled-pipe methods at (e)(1)(ii). You will meet that again in Part 4.

On the job: the fastest way to build a defensible chemical list is to walk the site and open doors. Gang boxes, the paint locker, the fuel cage, the janitor's closet, the shop fridge, the parts washer, the welding gas rack. If it is known to be present and someone could be exposed under normal use or in a foreseeable emergency, it is in scope.

3 Construction, laboratories and sealed containers

Three scope questions come up constantly, and the standard answers all three.

Construction. 29 CFR 1926.59 adopts 1910.1200 for construction work. The written program, the labels, the safety data sheets and the training are identical. There is no lighter construction version of HazCom.

Laboratories. Paragraph (b)(3) applies the standard to laboratories only as follows: labels on incoming containers are not removed or defaced; safety data sheets received with incoming shipments are maintained and readily accessible during each work shift to laboratory employees in their work areas; employees get information and training under paragraph (h), except the part about the location and availability of the written program; and a laboratory that ships hazardous chemicals is treated as a manufacturer or distributor and must label what leaves and supply sheets under (g)(6) and (g)(7).

Sealed containers. Paragraph (b)(4) covers work operations where employees only handle chemicals in sealed containers which are not opened under normal conditions of use — the standard names marine cargo handling, warehousing and retail sales. There, the duties are: do not remove or deface incoming labels; keep any safety data sheets that arrive, obtain one as soon as possible if an employee asks for a sealed container that came without one, and keep them readily accessible each shift; and provide information and training under (h) — again minus the written-program location item — to the extent necessary to protect employees in the event of a spill or leak.

How far the standard reaches, by setting
Setting	What applies	Paragraph
General industry	All of it	1910.1200(b)(1)-(2)
Construction	All of it, adopted by reference	1926.59
Laboratory	Labels intact, SDS kept and accessible, (h) training minus (h)(2)(iii), shipping duties if it ships	1910.1200(b)(3)(i)-(iv)
Sealed containers only (warehousing, retail, marine cargo)	Labels intact, SDS kept and obtainable on request, (h) training to the extent needed for a spill or leak	1910.1200(b)(4)(i)-(iii)

4 What the standard does not cover

There are two different exclusion lists and they are easy to confuse.

Paragraph (b)(5) removes only the labeling requirement, for products already labeled under another federal law: pesticides subject to FIFRA labeling and EPA's labeling regulations; chemical substances and mixtures subject to TSCA labeling; and foods, food additives, color additives, drugs, cosmetics and medical or veterinary devices under the Federal Food, Drug, and Cosmetic Act. Those products still need safety data sheets and training where they are hazardous chemicals in the workplace. Only the label duty falls away, because another agency already governs the label.

Paragraph (b)(6) removes the section entirely for a different list: hazardous waste regulated under RCRA; a CERCLA hazardous substance that is the focus of remedial or removal action under EPA regulations; tobacco and tobacco products; wood or wood products whose only hazard is flammability or combustibility — with the standard adding expressly that treated wood, and wood which may be subsequently sawed or cut generating dust, are not exempt; articles as defined in paragraph (c); food and alcoholic beverages sold, used or prepared in a retail establishment and food for employees' personal consumption; drugs in solid final form for direct administration, retail over-the-counter drugs and employees' personal drugs including first aid supplies; and retail-packaged cosmetics and employees' personal cosmetics.

Common mistake: treating “lumber is exempt” as a rule of thumb. The wood exclusion holds only where the sole hazard is flammability or combustibility. Pressure-treated lumber carries a hazardous chemical, and any wood that will be cut on site generates dust. The standard writes both exceptions into the exclusion itself.

5 The four deliverables, and how the rest of this course is laid out

Strip the standard down and an employer who buys chemicals owes four things. Everything in this course maps onto them.

1
A written hazard communication program that describes how the label, safety data sheet and training criteria will be met, plus the chemical list and the methods for non-routine tasks and unlabeled pipes — paragraph (e). Chapter 1.3.
2
Labels and other forms of warning, on what arrives and on what you fill yourself — paragraph (f) and mandatory Appendix C. All of Part 2.
3
Safety data sheets, obtained, maintained and readily accessible during each work shift — paragraph (g) and mandatory Appendix D. All of Part 3.
4
Information and training, at initial assignment and whenever a new chemical hazard arrives — paragraph (h). Chapter 1.4, then applied throughout Part 4.

One more thing worth knowing now: HazCom is the hub that the substance-specific standards plug into. The silica standard requires respirable crystalline silica to be folded into the HazCom program, addressing cancer, lung effects, immune system effects and kidney effects (1926.1153(i)(1)). The lead standard does the same with five named effects (1926.62(l)(1)(i)). The asbestos standard requires asbestos in the program with cancer and lung effects (1926.1101(k)(1)(ii)). Your HazCom program is where those obligations land.

6 Why it gets cited

Being second on OSHA's Top 10 list for fiscal year 2025 — the period from October 1, 2024 to September 30, 2025 — tells you something about where the failures cluster. They are rarely exotic. They are a written program that was downloaded and never edited, so it names a chemical list that does not exist. They are a secondary container with a strip of masking tape on it. They are a binder of safety data sheets locked in an office nobody on the night shift can enter. They are training that happened at hire and never again, in a work area where three new products arrived last quarter.

None of those are hard problems. They are maintenance problems, and the standard is written so that maintaining them is possible: the list is allowed to be per work area, the sheets are allowed to be electronic, the training is allowed to be by hazard category. What is not allowed is letting the information stop moving.

Key takeaways

HazCom moves information; it sets no exposure limits and bans no chemical.
Manufacturers and importers classify, distributors transmit, all employers run a program and train.
Scope is any chemical present so that employees may be exposed under normal use or in a foreseeable emergency.
Construction is covered identically through 1926.59; laboratories and sealed-container operations get reduced duties, not none.
(b)(5) removes only the labeling duty for products labeled under other federal laws; (b)(6) removes the section entirely for a different list.
The four deliverables are the written program, labels, safety data sheets and training.

Free educational content — not OSHA-authorized training, no certificate or card issued. Follow your employer's program and the standards cited.