What an OSHA Inspector Checks for HazCom — and How to Be Ready in One Afternoon

Most HazCom citations are not about exotic chemistry. In our dataset, 98 of 138 federal HazCom citations — about 71% — are for the written program or for training: the two things an inspector checks by reading a document and talking to your people. OSHA publishes exactly how its compliance officers inspect for HazCom, in directive CPL 02-02-079, updated on May 19, 2026 for the current standard. This guide walks through what that directive tells them to do, and how a small site can get ready for it in one afternoon.

1. The written program: read, then checked against the floor

The directive tells inspectors to review the written program to see whether it covers the labeling, safety data sheet and training requirements and has been implemented in the workplace, while also watching for problems on the walkaround. A program that describes a system nobody follows does not pass.

• The chemical inventory must list a product identifier for each hazardous chemical known to be present, matching the label and the safety data sheet. It can cover the whole facility or individual work areas, and it must include chemicals that are only stored, not just the ones in use.
• Access: the program can be on paper or electronic, but employees must know how to reach it and there must be no barriers — the directive's own examples are a locked room, cabinet or computer.

2. Labels: legible, in English, and traceable

• Containers must carry the right information, and the labels must be legible and prominently displayed.
• Labels must be in English. Other languages may be added.
• The inspector checks that the product identifier on the label can be cross-referenced to the safety data sheet and to the inventory. This three-way match is where hand-written spray bottles and renamed products fail.
• If you use an in-house labeling system, its effectiveness is judged partly through employee interviews.

3. Safety data sheets: sampled, current, reachable

• Inspectors review a representative number of safety data sheets against your inventory list. They do not need to read every sheet to find the gaps.
• Each sheet must be the most current version your supplier provided. If you reordered a product after the manufacturer updated its sheet, keeping only the old one is not compliant.
• Sheets must be readily accessible to employees in their work area. If you rely on electronic access with no adequate backup for emergencies, the directive says that is cited under 1910.1200(g)(8).

4. Employee interviews: the part you cannot write down

The directive says the compliance officer must interview employees. They are not expected to recite their training word for word. They are expected to know the hazards they work with, how to find and use the information on labels and safety data sheets, and which protective measures to follow. An employer can be cited if the interviews show workers do not understand the hazards, even when the paperwork is in order. Inspectors also look at workers supplied by temporary agencies.

5. A four-hour plan for a small site

For a business with a few dozen chemical products, this is realistic in one afternoon:

1. Hour 1 — walk every area. List every container, including stored ones, using the product name exactly as it appears on the label.
2. Hour 2 — match each item to a safety data sheet. Flag missing and outdated sheets, and request the missing ones from the supplier in writing.
3. Hour 3 — label every secondary container with the product identifier and its hazards, and replace any label that has faded or smeared.
4. Hour 4 — update the written program so it names this site's actual chemical list, where the sheets are, who is responsible and how training is done. If the sheets are electronic, set up the backup now.
5. Then, over the next week, spend ten minutes with each employee on where the sheets are and how to read a label, and record who was trained, on what, and when.

Injury records are asked for too. If you keep OSHA injury and illness records, an inspector can ask for them, and 29 CFR 1904.40(a) requires copies within four business hours. Have the current OSHA 300 log, the last five years of logs, the 301 incident reports and the certified 300A summaries where you can produce them.

Frequently asked questions

Does an OSHA inspector check every safety data sheet?

No. OSHA's HazCom inspection directive (CPL 02-02-079) tells compliance officers to review a representative number of safety data sheets against the company's inventory list, and to check that each is current and readily accessible to employees in their work area.

Is an electronic SDS system acceptable to OSHA?

Yes, if employees can reach the sheets in their work area without barriers. The directive says a citation under 1910.1200(g)(8) is issued when an employer relying on electronic access has no adequate backup for emergencies, such as a power or network outage.

Will the inspector talk to my employees about HazCom?

Yes. The directive says the compliance officer must interview employees to judge whether they understand the chemical hazards in their work area, how to get and use information from labels and safety data sheets, and which protective measures to follow. Employees are not expected to recite their training, but an employer can be cited if the interviews show that workers do not understand the hazards.

Do we have to replace old MSDSs with new safety data sheets?

You must keep the most current version the manufacturer, importer or distributor provided. If you reorder a product after its manufacturer updated the sheet, keeping only the old version is not compliant. The directive also says HCS 2024 does not require employers to contact suppliers for new sheets for products they already have sheets for.

What should be in the chemical inventory?

A product identifier for every hazardous chemical known to be present, matching the label and the safety data sheet, including chemicals that are only stored and not in use. It can cover the whole facility or be kept by work area.

Source: OSHA Instruction CPL 02-02-079, Inspection Procedures for the Hazard Communication Standard (HCS 2024), effective May 19, 2026; 29 CFR 1910.1200. Citation counts are from SDSentry's dataset of federal OSHA HazCom citations (see the citation tracker).

Related guides

• What a written hazard communication program must contain
• The most-cited HazCom violations
• HazCom training requirements: what OSHA expects
• Secondary container labeling
• HazCom compliance checklist for small facilities
• OSHA Form 300A: the annual summary, posting and electronic submission
• OSHA required posters: what small employers must post
• Lockout/tagout requirements (29 CFR 1910.147) for small shops