What a Written Hazard Communication Program Must Contain

The written program is the single most-cited item in federal OSHA Hazard Communication enforcement — 52 of the 138 citations in our dataset, more than safety data sheets and labels combined. It is also the only one on that list you can fix with an afternoon and no purchase.

1. Why this one matters most

We track federal HazCom citations and publish them in our citation tracker. Across the 138 citations in that dataset (OSHA enforcement records, January 2025 to March 2026; checked Oct 2026), paragraph (e) — the written program — accounts for 52, about 38%. Training is next at 46. Safety data sheets account for 26 and labelling for 14.

Put plainly: the two cheapest things to fix are the two most likely to be written up, and the binder everyone worries about is not the main event. See the most-cited HazCom violations for the full breakdown.

2. What the standard actually asks for

29 CFR 1910.1200(e)(1) requires employers to “develop, implement, and maintain at each workplace, a written hazard communication program”. That program must at least describe how the criteria in paragraphs (f), (g) and (h) — labels and other forms of warning, safety data sheets, and employee information and training — will be met.

Beyond that description, the standard names two things the program must also include:

A list of the hazardous chemicals known to be present, using a product identifier that is referenced on the appropriate safety data sheet. The standard says this list “may be compiled for the workplace as a whole or for individual work areas”.
The methods you will use to inform employees of the hazards of non-routine tasks — the standard’s own example is cleaning a reactor vessel — and the hazards of chemicals in unlabeled pipes in their work areas.

That second item is the easiest one to overlook. A program can describe labels, sheets and training perfectly and still be incomplete because nobody wrote down how a worker is told about a once-a-year tank clean, or what is in the overhead pipe run.

3. If other contractors work on your site

Paragraph (e)(2) adds requirements for multi-employer workplaces — where you produce, use or store hazardous chemicals in a way that another employer’s employees may be exposed. The standard gives the example of a construction contractor working on site.

In that case the program must additionally include the methods you will use to:

provide the other employers on-site access to safety data sheets for each hazardous chemical their employees may be exposed to;
inform the other employers of any precautionary measures needed to protect employees, both in normal operating conditions and in foreseeable emergencies; and
inform the other employers of the labelling system used in the workplace.

This is the paragraph that applies whenever trades share a site. If you are a roofing, masonry or framing contractor sharing a site, these three points are part of your program, not optional extras.

4. Two things the standard permits that people assume it forbids

Paragraph (e)(3) states that an employer “may rely on an existing hazard communication program” to comply, provided it meets the criteria in paragraph (e). A programme you already have does not need rewriting from scratch if it genuinely covers what is required.

And the chemical list may be kept for the workplace as a whole or broken down by work area, whichever fits how you actually operate. Neither is more correct than the other.

5. Who has to be able to see it

Paragraph (e)(4) requires the employer to make the written program available, on request, to employees and their designated representatives. A program that exists but cannot be produced on request is doing only half its job — and “at each workplace” in (e)(1) is why a single copy at a head office is a weak position for a business that works on sites.

6. A short program is a legitimate program

Nothing in paragraph (e) sets a length. A business with four hazardous products needs a program covering four products. The failure that gets cited is not brevity — it is absence, or a generic template that does not describe what this workplace actually does.

The test worth applying: could someone who has never visited read your program and correctly say where your safety data sheets are kept, who trains new starters, what your labelling looks like, and what is on your chemical list? If not, that is the gap an inspector finds.

Frequently asked questions

What must a written hazard communication program contain?

Under 29 CFR 1910.1200(e)(1) it must describe how the criteria for labels, safety data sheets, and employee information and training will be met, and must also include a list of the hazardous chemicals known to be present using a product identifier referenced on the appropriate safety data sheet, plus the methods the employer will use to inform employees of the hazards of non-routine tasks and of chemicals contained in unlabeled pipes in their work areas.

Does a small business really need a written program?

The requirement in paragraph (e)(1) is to develop, implement and maintain one at each workplace; the standard sets no minimum size and no minimum length. A business with four hazardous products needs a program covering four products. In our citation data, absence of a program is the most-cited failure of all.

Can we use a template or an existing program?

Paragraph (e)(3) states that an employer may rely on an existing hazard communication program provided it meets the criteria in that paragraph. What gets cited is a generic document that does not describe what the workplace actually does — not the fact that it started from a template.

What extra applies if other contractors work on our site?

Paragraph (e)(2) covers multi-employer workplaces. The program must additionally include the methods used to give other employers on-site access to safety data sheets for chemicals their employees may be exposed to, to inform them of precautionary measures for normal operations and foreseeable emergencies, and to inform them of the labelling system used in the workplace.

Does the program have to be kept at the job site?

Paragraph (e)(1) requires it to be developed, implemented and maintained at each workplace, and paragraph (e)(4) requires it to be made available on request to employees and their designated representatives. For a business working across sites, a single copy at head office is a weak position.

SDSentry writes this program for you. It builds the written hazard communication program from your own chemical inventory — your company name, the person responsible, and the chemical list for each location, with the (e)(1) elements set out in order — ready to print or save as a PDF. Because it is produced from the live inventory, add a chemical and the next copy includes it. Training records with signatures, GHS secondary-container labels and a per-location safety data sheet library sit alongside it. 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.

Get the free chemical inventory template →

Most SDS software stops at the safety data sheets. OSHA HazCom asks an employer for five things: a written program, a chemical list, container labels, SDS access and employee training. SDSentry covers all five in one product and builds the written program from your own chemical list. See how 11 SDS tools compare on all five →

SDSentry keeps your SDS library, GHS labels and HazCom training records in one place — OSHA deadline price: $24 per location a month, or $199 a year (regularly $49). Start by November 20, 2026 to lock it in.

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