OSHA HazCom: The Most-Cited Violations and How to Avoid Them
Short answer: Hazard Communication is consistently one of OSHA's most frequently cited standards, year after year — and for small employers the same handful of problems come up again and again: no written program, no documented training, missing or inaccessible safety data sheets, unlabeled secondary containers, and no list of hazardous chemicals on site. The standard (29 CFR 1910.1200) applies in full no matter how small you are, and every one of these gaps is fixable. SDSentry ($24.99 per location per month) is built to close all five in one place — SDS library, GHS labels, documented training, a chemical inventory, and the written program — so a small business is inspection-ready without a full-time safety officer. Here is each violation, why it happens, and the fix.
1. No written hazard communication program — 1910.1200(e)
Why it happens: The written program is the requirement small employers most often miss entirely, because nobody is told they need one. There's no safety department, the chemicals "are just cleaning supplies," and the document was never created. When an inspector arrives, it is usually the first thing they ask for — and "we don't have one written down" is itself the citation.
The fix: Create a short written program under 29 CFR 1910.1200(e). It does not need to be long — it needs to describe how your workplace handles labels, safety data sheets, and training, name who is responsible for the program, and include a list of the hazardous chemicals on site. Keep it specific to your facility (a generic template with the blanks unfilled is a common follow-up citation) and keep it available to employees. See our HazCom compliance checklist for what to put in it.
2. No or inadequate employee information and training — 1910.1200(h)
Why it happens: Training in small shops tends to happen informally — a manager shows a new hire how things work and that's it. The training may even cover the right material, but it is never documented, and undocumented training is treated as no training during an inspection. Just as often the training never covers the specific hazards of the products in that work area, which the standard requires.
The fix: Train employees under 1910.1200(h) at initial assignment and whenever a new chemical hazard is introduced into their area. Cover how to read labels and SDSs, the physical and health hazards of the chemicals they work with, the protective measures and PPE, and the details of your written program. Then document who was trained, on what, and when — names, topics, and dates. Our HazCom training requirements guide walks through exactly what to cover and how to keep the records.
3. Missing or inaccessible safety data sheets — 1910.1200(g)
Why it happens: SDSs get lost. A binder goes missing, a product is reordered from a new supplier and never gets a sheet, or the SDS exists but is locked in a manager's office or on a computer employees can't reach. The standard requires that employees have ready access to the SDS for every hazardous product during each work shift, so "we have them, just not out here" is still a citation.
The fix: Under 1910.1200(g), keep a current safety data sheet for every hazardous product you use, and make sure employees can get to it readily during any shift — no locked offices, no "ask the manager." Modern SDSs follow the standard 16-section GHS format. Keep them current: when a manufacturer reformulates a product or you switch brands, the SDS changes too. An electronic library that the whole crew can open on a phone or shared screen solves both the "missing" and the "inaccessible" halves of this citation at once.
4. Unlabeled or improperly labeled secondary containers — 1910.1200(f)
Why it happens: Shipped containers usually arrive with their full manufacturer label, but the moment a product is poured into a spray bottle, bucket, or unmarked jug, that secondary container is often left blank or marked with only a handwritten name. Inspectors find these everywhere in small facilities — the cleaning cart, the shop bench, the back room.
The fix: Under 1910.1200(f), every container of a hazardous chemical must be labeled. Shipped containers need the full GHS label (product identifier, signal word, pictograms, hazard and precautionary statements, supplier information). Secondary containers need either the same information or, at minimum, the product identifier plus words, pictures, or symbols that convey the hazards. There is one narrow exception for a portable container used only by the worker who fills it and emptied by the end of their shift — our guide to secondary container labeling under GHS covers it. When in doubt, label it.
5. No chemical inventory / list of hazardous chemicals — 1910.1200(e)(1)(i)
Why it happens: Nobody ever sat down and wrote out what's actually on site. New products get bought, old ones get discontinued, and the list — if it ever existed — drifts out of date. The written program requires a list of the hazardous chemicals known to be present, and a stale or absent list is a frequent companion citation to the missing-program finding.
The fix: Maintain a current list of the hazardous chemicals in your workplace, required as part of the written program under 1910.1200(e)(1)(i). The inventory is the backbone of everything else: it tells you which SDSs you need, which labels and training topics apply, and whether you cross reporting thresholds like EPCRA Tier II. A by-location list also makes storage risks obvious — for example, keeping bleach away from ammonia and acids. Our guide on the five HazCom requirements ties the inventory back to the rest of the program.
How these violations connect
Notice that these five aren't separate problems — they're one system with five visible faces. Your chemical inventory determines which SDSs you need; your SDSs drive your labels and the hazards you train on; your written program documents all of it; and your training records prove people actually learned it. That's also why inspections rarely find just one of these in isolation — a facility missing the written program is usually missing the chemical list and the training records too. Fix them together and you close the whole cluster at once.
How SDSentry helps you avoid them
SDSentry is HazCom and SDS software built for small employers, and it maps directly onto the five citations above: a per-location SDS library with multi-source lookup and your own uploads (1910.1200(g)), printable GHS secondary-container labels (1910.1200(f)), per-product training guides with e-signature records (1910.1200(h)), a by-location chemical inventory (1910.1200(e)(1)(i)), and the written HazCom program (1910.1200(e)) — plus a no-login Shared SDS Binder so sheets are accessible during every shift. It's a flat $24.99 per location per month with unlimited users and a 14-day free trial, so a small business can get audit-ready without an enterprise EHS suite.
Frequently asked questions
What is the most common OSHA HazCom violation?
The citations that come up most often are a missing or generic written hazard communication program, no documented employee training, safety data sheets that are missing or not readily accessible, and unlabeled secondary containers. Hazard Communication is consistently one of OSHA's most frequently cited standards year after year. Verify the current details at osha.gov.
Why is HazCom cited so often in small businesses?
Most small employers do have hazardous chemicals — cleaners, solvents, disinfectants, pesticides — but no dedicated safety staff. The written program is never created, training happens informally and is never documented, and SDSs and labels fall out of date. The standard applies in full regardless of company size, so these gaps become citations during an inspection.
How do I avoid a HazCom citation?
Keep five things current: a written hazard communication program, a safety data sheet for every hazardous product that employees can reach during any shift, GHS labels on shipped and secondary containers, a list of the hazardous chemicals on site, and documented employee training. Keeping all five in sync is what an inspection checks for.
Where can I confirm OSHA's HazCom requirements?
The standard itself is 29 CFR 1910.1200. Read it and OSHA's guidance at osha.gov/hazcom, and confirm the rules and deadlines that apply to your workplace with a qualified safety professional. This guide is educational and not legal or compliance advice.