HazCom on the Jobsite: What OSHA Actually Cited in FY2025 Construction Inspections

On a construction site, OSHA writes the general industry number. In fiscal year 2025, federal inspectors issued 698 hazard communication citations to construction employers under 29 CFR 1910.1200, and 14 under the construction section, 1926.59. For respirators the split is starker: 356 citations under 1910.134, none under 1926.103. And when you read the paragraphs, the most-cited HazCom item on a jobsite isn't an unlabeled bucket. It's the written program.

In FY2025 federal construction inspections, OSHA issued 698 hazard communication citations under 29 CFR 1910.1200 and 14 under 1926.59; the most-cited paragraph was the written program requirement, 1910.1200(e)(1), with 283 citations, ahead of training under (h)(1) with 167.

At a glance (FY2025, federal OSHA, construction NAICS 23): 1910.1200: 698 citations on 340 inspections · 1926.59: 14 · 1910.134: 356 · 1926.103: 0 · top paragraph (e)(1) written program, 283 · roofers 34.7% · $984K in current penalties, 23.8% below proposed · 61 of 271 silica inspections also cited HazCom.

Which number goes on the citation

A contractor reads Part 1926. The inspector cites Part 1910. The data shows when, and the rule explains why.

The pattern is in the regulation itself. 1926.59 is one sentence: "The requirements applicable to construction work under this section are identical to those set forth at § 1910.1200 of this chapter." 1926.103 says the same of 1910.134. When the construction section is only a pointer, the citation goes to the text it points to. 1926.95 is different: it has its own paragraphs, including the 2025 fit rule and the payment rule, and inspectors cite it more than twice as often as 1910.132.

What that means for you: a construction HazCom program that only quotes 1926.59 quotes a sentence. The obligations, and the paragraph numbers on a citation, live in 1910.1200.

What was cited, paragraph by paragraph

Four paragraphs carry 91% of construction HazCom enforcement:

• (e)(1), the written program: 283. The employer shall "develop, implement, and maintain at each workplace, a written hazard communication program," with a list of the hazardous chemicals known to be present, using a product identifier referenced on the SDS ((e)(1)(i)). On a jobsite, "at each workplace" means that site. A binder in the office covering the company in general doesn't show the list for the job the inspector is standing on.
• (h)(1), training: 167. "Effective information and training on hazardous chemicals in their work area at the time of their initial assignment, and whenever a new chemical hazard the employees have not previously been trained about is introduced." New product on the truck, new training.
• (g)(8), access to SDSs: 108. Sheets "readily accessible during each work shift to employees when they are in their work area(s)." A phone with no signal on a basement pour, or a binder locked in the super's truck, fails that test.
• (g)(1), an SDS for each chemical: 78. "Employers shall have a safety data sheet in the workplace for each hazardous chemical which they use."

Labels, paragraph (f), sit in the remainder. The citations follow the paperwork an inspector can ask for in five minutes: show me the program, show me the list, show me the sheets, show me who was trained.

Who got cited

Roofers lead here for the same reason they lead fall protection: they're inspected. Our fall protection data shows three in four residential fall citations came from planned inspections, and once an inspector is on site the HazCom questions follow. Roofing primers, adhesives, sealants and fuel are hazardous chemicals like any other. Masonry is second, where the chemical is often the one in the bag: portland cement and crystalline silica.

How the HazCom inspection started

A third of these citations came from referrals and a third from planned inspections; complaints account for one in seven. Whatever opened the inspection, the written program is what got cited.

The penalties

• Proposed: $1,292,207 across 698 citations.
• Current, after settlements and contests: $984,061, 23.8% lower (what happens between proposed and current).
• Classification: 515 serious (73.8%), 144 other-than-serious (20.6%), 39 repeat (5.6%), no willful.

HazCom is ninth in construction citation counts, not first (why), and its dollars are small next to fall protection. But it rarely travels alone. The 698 citations came from 340 inspections, and 238 of them, 70%, carried citations under other standards too: most often fall protection (1926.501, 67 inspections), silica (1926.1153, 61), eye and face protection (1926.102, 59) and respirators (1910.134, 53).

Respirators: the same pattern, 356 to zero

The top two respirator citations are paperwork too: the medical evaluation and the written program. The detailed rules are on our respiratory protection hub.

Silica and HazCom travel together

Of 271 federal construction inspections that produced a citation under the silica standard, 1926.1153, 61 also produced a 1910.1200 citation, 22.5%. The link is written into the silica standard: 1926.1153(i)(1) requires the employer to include respirable crystalline silica in the program established to comply with HazCom. A silica exposure control plan without silica on the HazCom chemical list is one inspection away from two citations. More on the substances that carry their own standard: OSHA substance-specific standards.

What to fix first

1. Write the program for the site, with the site's list. 1910.1200(e)(1) and (e)(1)(i): each product by the identifier on its SDS. Our free HazCom program generator builds the document around your list.
2. Match the list to the sheets. One SDS per product used (g)(1), and a way to reach it during every shift in the work area (g)(8), including where the phone has no signal.
3. Train when the product changes, and record it. (h)(1) is triggered by a new hazard, not by the calendar. Run your own check with the HazCom audit checklist.
4. Put silica, cement and every task chemical on the list. 1926.1153(i)(1) puts silica there by rule.
5. If anyone wears a tight-fitting respirator, have the medical evaluation and the written program before the fit test: (e)(1) and (c)(1) are the first two things cited. The respirator medical questionnaire is free.

HazComFast keeps a chemical inventory for each jobsite, a versioned written HazCom program, and the SDS for every product one QR scan away on the container, with read receipts showing who opened which sheet, when, and in which language.

Methodology and limits

• Source. U.S. Department of Labor OSHA enforcement data, inspection and violation tables, retrieved September 26, 2026.
• Scope. Citations issued October 1, 2024 through September 30, 2025 on inspections of construction employers (NAICS 23) under federal jurisdiction; State Plan inspections and deleted citations excluded.
• Cross-check. OSHA's Frequently Cited Standards tool, extracted August 15, 2026, gives 698 citations under 1910.1200 and 14 under 1926.59 for the same scope, and $984,054 in current penalties.
• Paragraphs. As written on each citation item. "(e)(1)" adds the 262 items written as (e)(1) and the 21 written as (e)(1)(i); "(h)(3)" adds (h)(3) and its subparagraphs.
• Penalties. Proposed is the initial amount; current is the amount on record at extraction, after settlements and contests, not a payment ledger.
• Not measured. What exactly was missing in each program; the data records the paragraph, not the inspector's notes.

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Sources & verification (counts extracted September 26, 2026; regulatory texts read September 29, 2026): enforcement counts from the U.S. Department of Labor's OSHA enforcement data (data.dol.gov); 29 CFR 1910.1200(e)(1), (g)(1), (g)(8), (h)(1) and (h)(3), 1910.134, 1926.59, 1926.95, 1926.103 and 1926.1153(i)(1) read on the eCFR. Related: HazCom citations decoded, HazCom in construction under 1926.59 and the 1910.1200 standard page. General guidance, not legal advice.