The Contractor's Reality
For contractors, OSHA Hazard Communication (HazCom) is not just a regulatory hurdle; it is a daily operational challenge. Unlike factory work, where chemicals stay on a shelf, contractors move hazards from site to site. The 2026 updates to the standard add new layers of complexity that every contractor—from HVAC to masonry—must understand.
Key Deadlines for Contractors
Top 3 Contractor Risks
The "Van" Inventory
Chemicals stored in work vans are often forgotten. If a van is on the jobsite, it is part of the workplace. Those containers must be labeled, and those SDSs must be accessible.
Shared Hazards
If you are a sub, you must provide your SDSs to the GC. If you fail to do so, you create liability for the Controlling Employer and yourself.
Transient Workforce
High turnover means constant training. You cannot wait for the "annual meeting." New hires need HazCom training before their first shift.
The "Contractor Kit" Approach
To stay compliant, build a standard "HazCom Kit" for every crew:
1. A digital tablet with offline SDS access.
2. A "Red Binder" backup with the top 20 SDSs.
3. A roll of pre-printed GHS secondary container labels.
4. A copy of the written HazCom program.
By standardizing your approach, you ensure that whether your crew is at a residential remodel or a massive commercial build, their compliance travels with them.
Related: [Construction HazCom 1926.59](/blog/construction-hazcom-1926-59) · [Subcontractor Survival Guide](/blog/subcontractor-hazcom-compliance) · [OSHA HazCom for Contractors](/osha-hazcom-for-contractors)