Hazard Communication Standard (HCS): GHS Labeling Requirements

Worker in PPE inspecting a large chemical drum with visible GHS hazard label in an industrial warehouse, SDS binder on nearby table

Clear chemical labeling under OSHA’s Hazard Communication Standard aligned with GHS is central to preventing exposures and accidents in industrial settings. This article explains GHS label elements, regulatory responsibilities, practical implementation steps, common compliance pitfalls, and tools to improve labeling programs so safety teams can reduce risk, streamline inspections, and protect workers across plants, warehouses, and construction sites.

Why Hazard Communication and GHS matter in industrial workplaces

At the heart of workplace chemical safety is a single, foundational regulation from the Occupational Safety and Health Administration (OSHA). This rule, the Hazard Communication Standard (HCS) found in 29 CFR 1910.1200, establishes a worker’s “right to know” about the chemical hazards they face on the job. More than just a right to know, it’s a right to understand. To achieve this, OSHA aligned the HCS with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals, or GHS. This created a standardized, universal language for communicating hazards, ensuring that a label for a corrosive substance means the same thing in a Texas manufacturing plant as it does in a California warehouse or on a New York construction site.

The standard creates a clear chain of responsibility that begins long before a chemical reaches your facility. Chemical manufacturers and importers are tasked with the initial, critical step of evaluating the physical and health hazards of the chemicals they produce or import. Based on this classification, they must create GHS-compliant labels and Safety Data Sheets (SDSs) that accurately reflect those dangers. Distributors have the duty to pass this information downstream, ensuring every container they ship arrives with its original, compliant label intact.

Once a hazardous chemical arrives at an industrial workplace, the responsibility shifts to the employer. Your primary duties under the HCS are to maintain those supplier labels, develop a written hazard communication program, make SDSs readily accessible to employees, and, most importantly, provide effective training. This training must cover how to read and interpret the new label elements and SDS formats, understand the risks of the chemicals in their work area, and know the protective measures available to them. The system is designed so that the label on a drum serves as an immediate, at-a-glance warning, while the corresponding SDS provides the comprehensive details needed for safe handling, storage, and emergency response. The product identifier on the label must match the one on the SDS, creating a direct link between the two crucial documents.

In industrial settings, the need for this clarity is constant. Think of the typical risks. In a manufacturing plant, workers might handle solvents for cleaning parts, acids for metal treatment, or powdered coatings that pose respiratory hazards. Warehouse employees routinely manage pallets of cleaning agents, industrial lubricants, and reactive chemicals, where a small leak could lead to a major exposure event. On a construction site, workers use adhesives, sealants, paints, and concrete additives, often in confined spaces or areas with limited ventilation. Without a clear, standardized label, a container of flammable solvent could be mistaken for a harmless cleaner, or a worker might handle a corrosive material without proper gloves, leading to severe chemical burns. Accurate labels directly reduce these incidents by providing immediate, understandable warnings that cut through jargon and complexity.

Beyond the moral imperative to protect workers, there is a strong business case for rigorous HCS compliance. Fewer chemical-related injuries and illnesses translate directly to reduced workers’ compensation claims and lower insurance premiums. A well-run HazCom program minimizes costly production downtime that follows an incident and protects a company’s reputation. Furthermore, OSHA actively enforces these requirements. In 2023, HazCom was one of OSHA’s most frequently cited standards, resulting in over 3,200 citations and millions of dollars in potential penalties. A missing label on a secondary container or an outdated SDS is not a minor oversight; it is a citable offense that demonstrates a gap in the safety management system.

Finally, it is crucial to stay current. OSHA issued a final rule in 2024 to update the HCS, primarily aligning it with Revision 7 of the GHS. This update refines hazard classifications and improves the clarity of labels and SDSs. Compliance for these new rules is phased, with deadlines for manufacturers, importers, and distributors to comply for substances by January 19, 2026, and for mixtures by July 19, 2027. Employers must update their written programs and training to reflect these changes. Before implementing or overhauling your hazard communication program, always verify the latest requirements on the official OSHA Hazard Communication website. You should also check for any state-specific OSHA plans or industry-specific regulations that may impose additional requirements beyond the federal standard.

Key elements of GHS labels and what each means

A GHS-compliant label is more than just a sticker; it’s a concise, visual summary of a chemical’s hazards and the precautions needed to handle it safely. Under OSHA’s Hazard Communication Standard (HCS), specifically 29 CFR 1910.1200(f), every container of a hazardous chemical leaving a manufacturer or distributor must be labeled with six specific elements. Understanding each one is critical for ensuring your team can quickly and accurately assess risks.

Product Identifier
This is the unique name or number used for a hazardous chemical. It can be the chemical name, code number, or batch number, but it must be the exact same identifier used on the Safety Data Sheet (SDS). This direct link is non-negotiable; it allows a worker to quickly cross-reference the label with the more detailed information in the SDS. A common mistake is using an internal nickname or code on a workplace label that doesn’t match the supplier’s SDS, breaking that critical connection.

Signal Word
The signal word indicates the relative level of hazard severity. There are only two options, and only one will ever appear on a label.

  • Danger is used for the more severe hazards.
  • Warning is used for less severe hazards.

If a chemical has multiple hazards, the signal word corresponding to the most severe hazard is the one used. You will never see both on the same label. For example, a product that is both a skin irritant (Warning) and acutely toxic if swallowed (Danger) will only display “Danger.”

Hazard Statements
These are standardized phrases assigned to a hazard class and category that describe the nature of the hazard. For example, “Highly flammable liquid and vapor” or “Causes serious eye damage.” These statements are not written by the manufacturer; they are specific, harmonized phrases mandated by the GHS. Avoid using casual or non-standard language like “Can catch fire easily.” The goal is universal understanding, and sticking to the prescribed text is essential for compliance.

Pictograms
These are graphic symbols that provide an immediate visual cue about the chemical’s hazards. Each pictogram consists of a black symbol on a white background within a red diamond-shaped border. OSHA requires the use of eight specific pictograms.

  • Health Hazard Carcinogen, Mutagen, Reproductive Toxicity, Respiratory Sensitizer, Target Organ Toxicity, Aspiration Toxicity
  • Flame Flammables, Pyrophorics, Self-Heating, Emits Flammable Gas, Self-Reactives, Organic Peroxides
  • Exclamation Mark Irritant (skin and eye), Skin Sensitizer, Acute Toxicity (harmful), Narcotic Effects, Respiratory Tract Irritant
  • Gas Cylinder Gases Under Pressure
  • Corrosion Skin Corrosion/Burns, Eye Damage, Corrosive to Metals
  • Exploding Bomb Explosives, Self-Reactives, Organic Peroxides
  • Flame Over Circle Oxidizers
  • Skull and Crossbones Acute Toxicity (fatal or toxic)

While the GHS includes a ninth pictogram for environmental hazards (a tree and fish), OSHA does not enforce its use under the HCS. However, you may see it on products from international suppliers, and it’s good practice for workers to recognize it. The required pictograms are specified in Appendix C to 29 CFR 1910.1200, and OSHA provides a helpful quick reference guide, “Hazard Communication Standard: Labels and Pictograms.”

Precautionary Statements
These are standardized phrases that recommend measures to minimize or prevent adverse effects resulting from exposure. They are broken down into four types: prevention, response, storage, and disposal. Examples include “Wear protective gloves” (prevention) or “If in eyes, rinse cautiously with water for several minutes” (response). Like hazard statements, this wording is harmonized and should not be altered.

Supplier Identification
Every label must include the name, address, and telephone number of the chemical manufacturer, importer, or other responsible party. This ensures there is a clear point of contact for additional information or in case of an emergency.

Supplemental Information and Batch Identifiers
Labels may also include supplemental information, such as directions for use, personal protective equipment (PPE) suggestions, or batch/lot numbers. This information is permitted as long as it does not contradict or cast doubt on the required hazard information. Batch identifiers are particularly useful for quality control and traceability in the event of a product recall.

For a pure substance, the hazard classification is straightforward and directly maps to the required label elements. For mixtures, the process is more complex. The manufacturer must classify the mixture as a whole, considering the hazards and concentrations of its individual components according to the rules in 29 CFR 1910.1200. This final classification determines which signal word, statements, and pictograms are required.

Certain exceptions exist. Consumer products are exempt, but only when used in the workplace in a manner consistent with household use. Using a commercial-sized drum of a cleaning product, for instance, would not fall under this exemption. OSHA also provides guidance for labeling small containers where a full label is impractical, often allowing for tags or abbreviated labels as long as the full information is immediately available to the user. Shipped containers must always bear the full GHS label from the supplier, but employers have some flexibility for workplace or “secondary” container labels, which will be covered in the next chapter.

Given the ongoing updates to align the HCS with GHS Revision 7, it is crucial to stay current. Always check OSHA’s official Hazard Communication Standard page and the rulemaking page for the latest guidance, fact sheets, and compliance dates to ensure your labeling program remains effective and compliant.

Practical steps to implement compliant labeling in your facility

Transitioning your facility to full HCS GHS compliance is a systematic process, not an overnight fix. With the updated HCS 2024 rule now in effect, deadlines are approaching for substances (January 19, 2026) and mixtures (July 19, 2027). Breaking down the implementation into manageable steps ensures nothing is missed and your team is protected. This guide provides a practical roadmap for safety managers in any industrial setting.

Step 1. Conduct a Comprehensive Chemical Inventory and Hazard Review

Your first move is to know exactly what you have on-site. A thorough chemical inventory is the foundation of your entire hazard communication program. Go beyond a simple list of names; this inventory must be a dynamic tool.

  • Walk the Floor
    Physically walk through every area of your facility, including plants, warehouses, maintenance shops, and construction sites. Document every chemical product. Note its name, manufacturer, location, and container type.
  • Create a Master List
    Use a spreadsheet or a chemical management software to create a master chemical inventory list. This list should include the product identifier that matches the Safety Data Sheet (SDS).
  • Review Hazard Classifications
    For each chemical, obtain the most recent SDS from the supplier. Review Section 2 (Hazard Identification) to confirm its GHS classification. Your inventory should flag chemicals with high-severity hazards like carcinogenicity or acute toxicity for priority attention. This review is critical under the HCS 2024 update, which aligns with GHS Revision 7 and may introduce new hazard categories or classifications for your existing chemicals.

Step 2. Obtain and Reconcile Supplier Information

You are responsible for the information you provide to your employees, even if it originates from a supplier. Never assume a supplier’s label or SDS is correct and complete.

  • Establish a Receiving Procedure
    Implement a formal check for all incoming chemical shipments. The receiving team should verify that every container is labeled correctly and that the label information matches the accompanying SDS. Do not allow unlabeled or improperly labeled chemicals into your active inventory.
  • Reconcile Labels and SDSs
    Compare the supplier label on the container to the SDS. All six GHS elements must be present and consistent between the two documents. If you find a discrepancy, such as a missing pictogram on the label or a conflicting hazard statement, contact the supplier immediately for clarification. Document these communications and their resolution.
  • Address Trade Secrets
    If a supplier SDS withholds an ingredient’s identity as a trade secret, verify that the SDS still discloses all hazard information and that it includes a statement about the trade secret claim. Your written hazard communication program should note how to handle these chemicals and the procedure for requesting disclosure to a health professional in an emergency, as required by 29 CFR 1910.1200.

Step 3. Produce Compliant Workplace and Secondary Container Labels

Workplace or “secondary” container labels are one of the most common sources of HCS citations. Any time a chemical is transferred from its original shipping container into another container like a spray bottle, jug, or transfer drum, that new container must be labeled. The only exception is for a portable container intended for immediate use by the person who performed the transfer.

A compliant workplace label must contain, at a minimum, the product identifier and words, pictures, symbols, or a combination that provides general information about the chemical’s hazards. For clarity and best practice, many facilities opt to use labels that replicate the full six GHS elements from the supplier container, as permitted under 29 CFR 1910.1200(f)(6).

Sample Workplace Label Template (Basic)

Product Identifier: [Chemical Name as it appears on SDS]
Signal Word: [Danger or Warning]
Hazard Pictograms: [Insert Pictograms]
Hazard Statements: [e.g., Causes serious eye irritation.]

Sample Workplace Label Template (Detailed)

Product Identifier: ACME DEGREASER X-100
Supplier: ACME Chemical Co. (555) 123-4567

[Pictogram: Corrosion] [Pictogram: Exclamation Mark]

Signal Word: DANGER

Hazard Statements:
Causes severe skin burns and eye damage.
May cause respiratory irritation.

Precautionary Statements:
Wear protective gloves, clothing, and eye protection.
Use only outdoors or in a well-ventilated area.
Store in a locked, well-ventilated place.
IF SWALLOWED: Rinse mouth. Do NOT induce vomiting.

Step 4. Establish Procedures for Specific Scenarios

Your labeling program needs to account for the dynamic nature of industrial work.

  • Forklifts and Transfer Drums
    Large, mobile containers like drums on forklifts or portable tanks must be clearly labeled on all visible sides. The label must be durable enough to withstand the environment.
  • Temporary and Small Containers
    For very small containers like vials, where a full label is not feasible, use tags or place the labeled vials in a larger, clearly labeled outer container. For single-use or temporary containers used during maintenance, a durable tag with the product identifier and key hazards is a practical solution.
  • Multilingual Labeling
    If you have workers who do not read English, you must provide hazard information in a language they understand. This can be achieved by using bilingual labels or providing supplementary materials and training in their primary language. Use professional technical translation services to ensure the accuracy of hazard and precautionary statements.

Step 5. Integrate, Document, and Audit

A successful labeling program is integrated into your daily operations and is continuously verified.

  • Integrate with Technology
    Use barcodes or QR codes on your workplace labels. Scanning the code can link an employee directly to the full SDS on a mobile device or computer terminal. This dramatically improves access to information, especially in an emergency. Ensure the physical label still contains the essential GHS elements.
  • Documentation and Training
    Your written Hazard Communication Program must detail your entire labeling system. Train all employees on how to read the GHS labels, where to find SDSs, and the specific procedures for your workplace labeling system. Document all training sessions.
  • Establish an Audit Schedule
    Regular audits ensure your system remains effective. Use a simple checklist to formalize the process and track corrective actions.

Daily and Quarterly Inspection Checklist

Use this checklist to maintain labeling compliance.

Daily Checks (Area Supervisor)

  • Are all secondary containers (spray bottles, jugs) in my area labeled?
  • Are all labels legible and undamaged?
  • Are any new chemicals present that need to be added to the inventory?

Quarterly Audits (Safety Manager)

  • Is the master chemical inventory list accurate and up-to-date?
  • Have all new chemicals received in the last quarter been reconciled with their SDSs?
  • Are workplace labels consistent with the current SDS for a random sample of 5-10 chemicals?
  • Is the electronic SDS database fully functional and accessible to all shifts?
  • Are training records for new hires and newly introduced hazards complete?

Common compliance pitfalls and best practices to avoid citations

Even with a solid implementation plan, compliance can drift. It’s easy for small labeling mistakes to multiply across a facility, creating significant risk and opening the door for OSHA citations. Understanding the most common pitfalls is the first step toward preventing them. Let’s look at what inspectors frequently find and how you can build a more resilient program.

Frequent Labeling Mistakes and Corrective Best Practices

Missing Hazard Statements or Signal Words
A label might have a pictogram and product name but be missing the required signal word (Danger or Warning) or the specific hazard statements (e.g., “Causes serious eye irritation”). This often happens with in-house workplace labels where a template is incomplete. The best practice is to make it a rule that no workplace label is printed without first cross-referencing it with Section 2 of the Safety Data Sheet (SDS) to ensure all required elements are present.

Incorrect Pictograms
Using the wrong pictogram or adding ones that aren’t required can be just as confusing as omitting them. For example, using the Skull and Crossbones for a chemical that is an irritant (which requires the Exclamation Mark) overstates the hazard. Always pull the required pictograms directly from the supplier’s SDS. Don’t guess based on the chemical name or its use.

Inconsistent or Illegible Supplemental Information
While you can add extra information like PPE suggestions or internal codes, it cannot contradict or obscure the required HCS elements. A common mistake is using large, bold text for an internal lot number that overshadows the signal word. Best practice is to standardize the placement and font size for all supplemental information, keeping it secondary to the GHS-required text.

Failure to Label Secondary Containers
This is one of the most frequently cited HazCom violations. Workers transfer chemicals from a large drum into a smaller spray bottle or jug and fail to label it. The “immediate use” exemption is narrow; it only applies if the person who made the transfer uses it all immediately without leaving it unattended. The simplest and most effective best practice is a clear policy: If you set a container down, it must have a workplace label.

Reliance on Legacy NFPA/HMIS Markings
Many facilities still use the NFPA diamond or HMIS bars. While these can be used as supplemental information, they do not replace a GHS-compliant label. A common pitfall is having only an NFPA diamond on a secondary container. To correct this, ensure every container has a full HCS workplace label. Use legacy systems only as a familiar, secondary reference and train employees on how GHS labels are the primary source of hazard information.

Untranslated Labels for Non-English Speakers
If you have workers who do not read English, labels must be presented in a way they can understand. Simply providing English-only labels is a major compliance gap. The best practice is to identify the primary languages spoken in your facility and provide labels that include those languages. Combining translated text with universally understood pictograms is key to effective communication.

Discrepancies Between SDSs and Labels
An inspector will often pull an SDS and compare it to the label on the corresponding container. If the pictograms, signal words, or hazard statements don’t match, it’s an immediate red flag. This usually points to a failure in your receiving process or a poor change control system. The fix is to implement a receiving procedure where incoming chemicals are quarantined until the label is verified against the SDS.

Unlabeled Pipes and Process Lines
While HCS doesn’t require individual GHS labels along the entire length of a pipe, it does require that employees be aware of the hazards. A common failure is having no system at all. Best practice is to use a consistent labeling scheme (like text and color-coding) that identifies the chemical and its hazards at key access points, like valves and junctions. This system must be documented in your written HazCom program and covered in employee training.

Poor Change Control
When a supplier updates a chemical’s formulation, they issue a new SDS. A frequent mistake is updating the SDS in the binder or electronic system but failing to update the labels on containers in the facility. A robust Management of Change (MOC) process is the solution. Any new SDS should trigger a review of all associated workplace labels and a plan to update them promptly.

Enforcement Trends and Citation Examples

OSHA continues to focus heavily on the Hazard Communication Standard. In 2023 alone, there were over 3,200 HazCom-related violations, a significant increase from the previous year. Inspectors are trained to look for systemic failures, not just isolated mistakes. A typical citation might not be for a single unlabeled bottle but for the “failure to maintain a complete written hazard communication program,” which a pattern of unlabeled containers demonstrates. Another common citation is for “failure to provide effective employee training,” which an inspector might conclude if workers cannot explain the meaning of a pictogram on a label they use daily. The message is clear: OSHA is looking for a living, breathing program, not just a binder on a shelf.

A Prioritized Remediation Plan

If you’ve identified some of these pitfalls in your facility, use this three-tiered approach to get back on track.

1. Immediate Fixes (The Next 7 Days)

  • Walk the Floor: Grab a cart with a label printer and blank labels. Walk through every work area and immediately label any unlabeled or improperly labeled secondary containers.
  • Check New Receipts: Go to your chemical receiving area. Pull the SDS for the last five chemicals that arrived and verify their labels are complete and match the SDS.
  • Hold a Toolbox Talk: Gather your teams for a brief refresher on your secondary container labeling policy. Emphasize the “if you set it down, label it” rule.

2. Medium-Term Process Changes (The Next 90 Days)

  • Update Your Written Program: Formally document your procedures for secondary container labeling, pipe marking, and verifying incoming labels.
  • Implement Checklists: Introduce simple checklists for chemical receiving and for weekly area inspections. (See templates below).
  • Review Supplier Performance: Identify any suppliers who consistently send products with non-compliant labels or outdated SDSs. Contact them to demand correction.

3. Long-Term Cultural Actions (Ongoing)

  • Integrate HazCom into Training: Move beyond one-time HazCom training. Incorporate label review into job-specific training and safety refreshers.
  • Conduct Formal Audits: Schedule quarterly HazCom audits with a scoring system to track improvement over time. Make the results visible to area supervisors to drive accountability.
  • Establish Supplier Agreements: For new chemical contracts, include language that requires suppliers to provide GHS-compliant labels and up-to-date SDSs as a condition of the agreement. For more information on the latest requirements, you can review OSHA’s final rule updates at their official site: OSHA’s Final Rule to Amend the Hazard Communication Standard.

Templates for Verification and Auditing

Use these simple templates to build consistency into your program.

Template: Weekly Workplace Labeling Verification Checklist

Check Point Yes/No Comments / Corrective Action Taken
Are all secondary containers (spray bottles, jugs, etc.) labeled?
Do all workplace labels include a product identifier and hazard info?
Are all labels legible and undamaged?
Are any legacy NFPA/HMIS labels present without a GHS label?

Template: Quarterly Internal Audit Scoring

Audit Area Criteria (1-5, 5=Excellent) Score Notes
Written Program Program is current, accessible, and reflects actual practice.
SDS Accessibility Employees can quickly access the correct SDS for any chemical.
Supplier Labeling Incoming chemicals are properly labeled and match their SDS.
Workplace Labeling Secondary containers, process lines, and tanks are correctly labeled.
Employee Training Employees can explain label elements and locate SDSs.
Total Score / 25 Goal: 22+

Frequently Asked Questions about HCS and GHS labeling

Even with a solid Hazard Communication Program, specific questions always come up during safety meetings and floor inspections. This section addresses some of the most common queries we see from safety teams trying to navigate the details of HCS and GHS labeling in a practical, day-to-day setting.

Do GHS labels apply to pipes and process lines?
No, you are not required to affix a full, six-element GHS label to every pipe in your facility. However, you absolutely must communicate the hazards of the chemicals inside them. OSHA allows for alternative methods for stationary process containers. Your responsibility is to ensure employees can identify the chemical and its hazards at a glance.

  • Actionable Steps
    Implement a consistent and clear system using signs, placards, tags, or color-coding that identifies the contents and associated hazards. For example, a tag could list the chemical name and display relevant pictograms. Ensure this system is documented in your written Hazard Communication Program and that all employees, including contractors, are trained to understand it. The key is that the hazard information must be readily available to workers in their work areas throughout each shift.
  • CFR Reference
    OSHA’s allowance for alternative labeling on stationary process containers is found in 29 CFR 1910.1200(f)(7).
  • When to Seek an Expert
    If you are designing a comprehensive pipe marking system for a complex plant, consult a safety engineer. They can help ensure your system is effective, compliant, and integrates with other industry standards like ANSI/ASME A13.1 for pipe identification.

How should mixtures be labeled when components have different hazards?
The label for a chemical mixture must represent the hazards of the mixture as a whole, not just a list of ingredient hazards. The manufacturer is responsible for performing this hazard classification. If they have test data on the final mixture, they use that. If not, they use established toxicological principles, such as concentration thresholds for hazardous ingredients, to classify the final product.

  • Actionable Steps
    As an end-user, you rely on the supplier’s label. It should display a single signal word (“Danger” always overrides “Warning” if both apply), along with all necessary pictograms and statements for the mixture’s complete hazard profile. If you create your own mixtures on-site (e.g., cleaning solutions), you become the manufacturer and are responsible for creating a compliant HCS label for the new mixture.
  • CFR Reference
    The complex rules for classifying mixtures are detailed in Appendix A and Appendix B of 29 CFR 1910.1200.
  • When to Seek an Expert
    Classifying mixtures is a highly technical task. If you are creating and packaging your own chemical products, work with an industrial hygienist or toxicologist to ensure your classifications and labels are accurate.

What are the translation requirements for a multilingual workforce?
OSHA’s standard is performance-based it requires that your training and information be presented in a language and vocabulary that employees can understand. While the regulation doesn’t explicitly state that every label must be translated, it is often impossible to meet the training requirement without doing so. If an employee cannot understand the label, they have not been effectively informed of the hazards.

  • Actionable Steps
    First, identify the languages spoken in your workforce. Provide all HCS training, including the meaning of label elements, in those languages. For high-hazard or frequently used chemicals, consider using bilingual labels or adding supplemental translated labels to containers. Pictograms are a powerful tool here, as they transcend language barriers, so emphasize them in your training.
  • CFR Reference
    The requirement for understandable training is in 29 CFR 1910.1200(h). OSHA has clarified in official Letters of Interpretation that this extends to language and literacy levels.
  • When to Seek an Expert
    For critical safety information, use a professional translation service that specializes in technical safety content. In cases of high liability or complex workforce dynamics, consult with legal counsel to ensure your communication methods are robust and defensible.

How do trade secret claims affect label content?
A manufacturer can legally withhold the specific name of a chemical ingredient if it qualifies as a trade secret. However, they can never withhold information about the hazards. The label must still communicate the full danger of the product, even if an ingredient is not named.

  • Actionable Steps
    The label on a product with a trade secret ingredient will still have all the required pictograms, the correct signal word, and all applicable hazard and precautionary statements. The SDS will note that an ingredient’s identity is withheld. Be aware that in a medical emergency, the manufacturer must disclose the trade secret information to treating physicians or nurses.
  • CFR Reference
    Trade secret provisions are detailed in 29 CFR 1910.1200(i).
  • When to Seek an Expert
    If you are a manufacturer making a trade secret claim, you must work with legal counsel. The criteria are very specific, and the documentation and disclosure procedures must be followed precisely to be compliant.

How often must training be provided that covers labels?
OSHA requires HCS training at two specific times when an employee is first assigned to a job involving hazardous chemicals, and whenever a new type of hazard is introduced into their work area. The standard does not mandate a specific annual or biennial refresher schedule. A “new hazard” means a hazard an employee has not been trained on before, which could come from a new chemical or a change in an existing one.

  • Actionable Steps
    Ensure every new hire receives comprehensive HCS training before starting their work. Implement a management of change process to trigger retraining when new hazards are introduced. Although not required by the letter of the law, conducting annual refresher training is a widely accepted best practice to ensure knowledge retention and a strong safety culture. Always document every training session.
  • CFR Reference
    Training frequency is covered in 29 CFR 1910.1200(h)(1).
  • When to Seek an Expert
    Work with a safety training professional to design an engaging and effective training program. They can help you create content that meets OSHA requirements and truly helps employees understand and respect chemical hazards.

What if an SDS and a supplier label disagree?
A discrepancy between a label and its corresponding SDS is a red flag. The information must be consistent for the system to work. If you find a conflict, you must investigate and resolve it before allowing the chemical to be used.

  • Actionable Steps
    First, remove the chemical from service and label it “Do Not Use – Pending Investigation.” Contact the supplier immediately, provide details of the discrepancy, and request corrected and compliant documents. Document all your communications. If the supplier is uncooperative, you cannot use the chemical. In the interim, you must communicate the more protective hazard information to your employees until the conflict is resolved.
  • CFR Reference
    The entire HCS is built on the principle that the label and SDS are consistent, as required by 29 CFR 1910.1200(f) and (g). The product identifier on both must match exactly.
  • When to Seek an Expert
    If you have a critical supplier who repeatedly provides non-compliant or conflicting documents, it is time to consult legal counsel. They can advise you on your obligations as an employer and the potential liabilities of using improperly documented chemicals.

Conclusions and next steps for stronger hazard communication

Effective hazard communication is not a static, check-the-box exercise. It is a dynamic process that forms the bedrock of a safe industrial workplace. The consistent and accurate application of GHS-aligned labels under OSHA’s Hazard Communication Standard is the most direct way to empower workers with the information they need to protect themselves. Clear labels prevent chemical exposures, reduce the frequency of injuries, and minimize costly production downtime. Beyond the immediate benefit to employees, a robust labeling program is a non-negotiable component of regulatory compliance, shielding your organization from significant penalties that have been on the rise. In an emergency, whether a spill, fire, or medical incident, these labels provide first responders with immediate, life-saving information, enabling a faster and more effective response. Moving from theory to practice requires a deliberate, prioritized plan.

For safety leaders looking to strengthen their facility’s hazard communication program, the following steps provide a clear path forward. This is not just about meeting minimum requirements but about building a resilient safety culture.

  • Immediate Actions (Next 30 Days)
    Your first priority is to assess your current state of compliance and address any immediate risks. Start with a walk-through of your facility, focusing on high-traffic and high-risk areas like chemical storage rooms, decanting stations, and production lines. Spot-check at least 10-15% of your incoming supplier labels to ensure all six required GHS elements are present and legible. Pay special attention to secondary containers. Are they properly labeled with at least the product identifier and words, pictures, or symbols that provide general information about the chemical’s hazards? Confirm that your Safety Data Sheet (SDS) library, whether physical or electronic, is readily accessible to all employees on all shifts. Any gaps found in these areas represent significant compliance risks and should be corrected immediately.

  • Medium-Term Program Updates (Next 3-6 Months)
    With immediate risks managed, focus on systemic improvements. The most critical task is to review and update your written Hazard Communication Program. This document must reflect the latest changes from OSHA’s 2024 final rule, which aligns the HCS with GHS Revision 7. Your program should detail your procedures for workplace labeling, SDS management, and employee training. This is also the time to standardize your workplace labeling system. If you use an alternative to supplier labels, such as an in-house system with color codes or pictograms, ensure it is documented, consistent across the facility, and fully understood by all employees through training. Begin planning for the upcoming compliance deadlines for the updated HCS. Manufacturers and importers must comply for substances by January 19, 2026, and for mixtures by July 19, 2027. Your facility will need to be prepared to manage these updated labels and SDSs as they arrive.

  • Long-Term Strategy (Ongoing)
    A strong hazard communication program requires continuous maintenance and improvement. Establish a recurring training schedule that goes beyond initial assignment. Provide refresher training annually and ensure immediate training occurs whenever a new chemical hazard is introduced. Develop a formal supplier management process. This should include a procedure for vetting new chemical suppliers and verifying the quality of their labels and SDSs upon receipt. Create a clear protocol for what to do when an SDS and a supplier label disagree. This process should involve contacting the supplier for clarification, documenting the discrepancy and its resolution, and quarantining the chemical if necessary until the hazard information is confirmed. This proactive approach to supplier management prevents downstream confusion and risk.

To ensure your program remains effective, integrate routine verification practices into your safety management system. Conduct quarterly internal audits of your chemical inventory, labels, and SDS library. This process, known as SDS reconciliation, involves comparing your chemical inventory list against your SDS collection to ensure you have a current, accurate SDS for every hazardous chemical on site. During these audits, check for damaged or illegible labels in storage areas and at points of use, replacing them as needed. Documenting these audits and any corrective actions taken is crucial.

Finally, the regulatory landscape is always evolving. Make it a practice to consult official resources to stay informed of any new interpretations or upcoming changes. The official OSHA Hazard Communication page is the primary source for guidance. As you update your written program, labels, or training materials to align with new requirements, document every change. Meticulous record-keeping is your best defense during an OSHA inspection and demonstrates a tangible commitment to worker safety.

References