HazCom for Machine Shops: What OSHA Actually Cites

Machine shops are the most-cited trade in our dataset of federal OSHA Hazard Communication citations — 18 of 138. What is surprising is what they get cited for. Two thirds of those citations are not about missing safety data sheets at all.

1. What the citation data actually shows

We track federal OSHA HazCom citations and publish them in our citation tracker. Filtering to NAICS 332710 (machine shops) for citations issued between January 2025 and March 2026 gives 18 citations across five states — Alabama (7), Texas (5), Ohio (3), Colorado (2) and Pennsylvania (1). Eleven were classified Serious.

Broken down by which paragraph of 29 CFR 1910.1200 was cited:

Twelve of the eighteen — two thirds — were for the written program or for training. Only three were for safety data sheets. That is the opposite of how most shops prepare: the binder gets attention because it is visible, while the written program and the training records are what inspectors actually write up.

2. The written program is a document, not a binder

Paragraph (e) requires a written hazard communication program. A shelf of safety data sheets is not one. The program is the document that describes how your shop handles labels, safety data sheets and training, and it has to reflect what you actually do.

This is the single most-cited item for machine shops in our data, tied with training. It is also the cheapest to fix, because it is a writing task rather than a purchasing one.

3. Training: what triggers it, and what does not

Paragraph (h) is the other half of the two thirds. The standard is specific about timing. Training is 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”.

For a machine shop the practical trigger is the second one. Swapping coolant brands, bringing in a different parts-washer solvent, or starting to weld a material you have not welded before all introduce a hazard employees may not have been trained on.

4. Labels and safety data sheets

Labels are paragraph (f), and safety data sheets are paragraph (g). Together they account for six of the eighteen citations.

In a machine shop the usual gaps are containers that were filled from a drum and never labelled — parts washers, spray bottles of degreaser, coolant top-up jugs — and safety data sheets that exist somewhere in the office but are not reachable from the shop floor during the shift in which they would be needed.

5. Which chemicals to inventory first

Start with what is decanted, mixed or consumed rather than what is stored:

• Metalworking and cutting fluids, and the concentrate they are mixed from
• Parts-washer solvent and degreasers
• Welding consumables and shielding gases
• Quench and way oils, rust preventatives
• Aerosols — brake cleaner, penetrating oil, layout dye

Whether a particular product is covered depends on whether it meets the definition of a hazardous chemical, and paragraph (b) sets out the scope and the exclusions — including a labelling exemption at (b)(5)(v) for certain consumer products. If you are unsure whether something in your shop is in or out, that paragraph is where the answer lives.

6. A realistic order of work

1. Write the program. It is the most-cited item and needs no purchase.
2. Record who was trained, when, and on what — especially new starters.
3. Walk the floor and label every container that was filled from something else.
4. Make safety data sheets reachable from the floor, not only from the office.
5. Add a step to your purchasing routine: a new chemical means a new sheet and a training note.

Frequently asked questions

What do machine shops actually get cited for under OSHA HazCom?

In our dataset of federal HazCom citations issued to NAICS 332710 employers between January 2025 and March 2026, 12 of 18 citations were for the written hazard communication program (paragraph (e)) or for employee information and training (paragraph (h)). Only 3 were for safety data sheets.

Does OSHA require annual HazCom refresher training?

The word “annual” does not appear in 29 CFR 1910.1200. The standard requires training 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. Yearly refreshers are common practice but are not what the paragraph requires.

Is a binder of safety data sheets the same as a written program?

No. Paragraph (e) requires a written hazard communication program describing how the workplace handles labels, safety data sheets and training. A collection of safety data sheets is not that document, and the written program was the most-cited item for machine shops in our data.

Which machine-shop chemicals need to be inventoried first?

Start with what is decanted, mixed or consumed rather than what sits sealed in storage: metalworking and cutting fluids and their concentrates, parts-washer solvent and degreasers, welding consumables and shielding gases, quench and way oils, and aerosols such as brake cleaner. Whether a specific product is covered depends on the scope and exclusions in paragraph (b).

Related guides

• HazCom checklist for auto body and collision shops
• HazCom training requirements: what OSHA expects
• The most-cited HazCom violations
• The federal HazCom citation tracker
• Argon SDS: Welding Gas Hazards, Cylinder Storage and Where to Get It
• Acetylene SDS: Hazards, Cylinder Rules and Where to Get the Current Sheet
• Lockout/tagout requirements (29 CFR 1910.147) for small shops