HazCom for Framing Contractors: Five of Seven Citations Were the Same Failure

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Framing contractors appear seven times in our dataset of federal OSHA Hazard Communication citations. Five of those seven were the same thing: no written hazard communication program. That is the tightest concentration on a single paragraph of any trade with five or more citations in our data.

1. What the citation data shows

We track federal OSHA HazCom citations and publish them in our citation tracker. Filtering to NAICS 238130 (Framing Contractors) for citations issued between January 2025 and March 2026 gives seven citations, all in Missouri, four of them Serious, carrying $11,207 in penalties.

By paragraph of 29 CFR 1910.1200:

ParagraphSubjectCitations
(e)Written hazard communication program5
(h)Employee information and training1
(g)Safety data sheets1

Across our whole dataset the written program accounts for a bit over a third of citations. In framing it is more than seven in ten.

2. Why framing skips the program

Framing is the trade where the “we do not really use chemicals” assumption is most understandable. The work is lumber, fasteners and tools. Nothing gets mixed, and on most days nothing gets sprayed.

But a written program is not a response to how many chemicals you hold. Paragraph (e) requires a written hazard communication program for a workplace where employees may be exposed to hazardous chemicals at all. A short, accurate program covering three products is entirely legitimate. Having none, because the list felt too short to bother with, is what gets cited.

This is the cheapest citation in our entire dataset to avoid. It requires no purchase, no equipment and no consultant — only writing down what you already do. It is also the most-cited paragraph across our dataset as a whole.

3. What is actually on a framing site

Whether a given product is in scope depends on the definitions and exclusions in paragraph (b), which is also where the labelling exemption for certain consumer products sits, at (b)(5)(v). That exemption is worth reading rather than assuming: it turns on the conditions of use, not simply on whether a product can also be bought in a shop.

4. Training and sheets: one citation each

Paragraph (h) covers employee information and training, required “at the time of their initial assignment, and whenever a new chemical hazard the employees have not previously been trained about is introduced into their work area”. Paragraph (g) covers the safety data sheets themselves.

There is no annual refresher in the standard. The word “annual” does not appear anywhere in 29 CFR 1910.1200. On a framing crew the trigger is a new hire, which in this trade can mean several times in a season.

5. A realistic order of work

  1. Write the program. In this trade it is more than seven in ten of the citations.
  2. List what is actually on the truck and in the trailer — it will be shorter than you expect.
  3. Get the sheets for those products and keep them with the crew.
  4. Record training for new hires before their first day on site.
  5. Label anything decanted, including fuel containers.

Frequently asked questions

What do framing contractors get cited for under OSHA HazCom?

In our dataset of federal HazCom citations issued to NAICS 238130 employers between January 2025 and March 2026, 5 of 7 were for the written hazard communication program (paragraph (e)), with one each for employee information and training (paragraph (h)) and safety data sheets (paragraph (g)).

Do we need a written program if we barely use chemicals?

Paragraph (e) requires a written hazard communication program for a workplace where employees may be exposed to hazardous chemicals. A short, accurate program covering a handful of products is legitimate. Having none because the list felt too short is what gets cited, and it was five of the seven citations in this trade.

What chemicals does a framing crew actually have?

Typically construction and subfloor adhesives, wood preservative and end-cut solution for treated timber, spray and marking paint, fuel cells for gas-actuated nailers, two-part foam and sealants, and petrol or two-stroke mix for saws and generators.

Does a framing crew need annual HazCom refresher training?

The word “annual” does not appear in 29 CFR 1910.1200. Training is required at the time of an employee's initial assignment, and whenever a new chemical hazard they have not previously been trained about is introduced into their work area. On a framing crew the trigger that fires most often is a new hire.

SDSentry keeps these in one place — the written program, training records with signatures, GHS secondary-container labels and a per-location safety data sheet library your people can reach. Start a free trial, or run the free 2-minute HazCom self-audit first.

Related guides

Start with the chemical list
A HazCom program starts from a list of the hazardous chemicals at your site. Download the free chemical inventory list template as a CSV for Excel or Google Sheets, or as a printable PDF. Free, no signup.
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