Is a written HazCom program required by OSHA?

Yes. 29 CFR 1910.1200(e) requires employers to have a written Hazard Communication Program that describes how they meet the standard (labels, SDS, training, inventory).

What must the 2026 written program include for GHS Rev 7?

Your plan must explicitly acknowledge the new hazard classifications (Chemicals Under Pressure, Desensitized Explosives). If you use the 100ml or 3ml labeling exemptions, document this policy and how workers are trained.

Write an OSHA HazCom Program in 10 Minutes: A Template

The Myth of Complexity

A Written Hazard Communication Program is often viewed as a bureaucratic nightmare, but OSHA's requirement under 29 CFR 1910.1200(e) is actually a request for a simple roadmap. The agency wants to know how you will manage chemical safety on your site. You can draft a compliant, site-specific program in under 10 minutes by focusing on the mandatory elements rather than unnecessary fluff.

Minute 0–3: The Scope and Responsibility

Start with a standard template. Your first task is to define who and where.

Company Name:
Program Administrator: (e.g., Site Safety Officer). This person is legally responsible.
Location: Where is the program kept? (e.g., "Main Site Office – Safety Shelf").
Regulatory Check: 1910.1200(e)(1) requires the program to describe how the criteria for labels, SDSs, and training will be met.

Minute 3–6: The "How-To" Procedures

This is the meat of the document. Customize the boilerplate to match your actual site reality.

1. Labeling Procedure

"The Site Supervisor will verify that all incoming containers have GHS-compliant labels."
"Secondary containers will be labeled using [method] that include the Product Identifier and Hazard Warnings."

2. SDS Access

"SDSs are maintained [location]."
"Employees can access them [on the tablet in the breakroom / by asking the foreman]."
Critical: "A backup system is available in case of power or internet failure."

Minute 6–8: The "Construction Clauses"

These are the most frequently cited missing elements for construction companies.

Non-Routine Tasks

Draft a statement: "Before performing non-routine tasks (e.g., tank cleaning), the Supervisor will review specific hazards and safety measures with affected employees."

Multi-Employer Worksite (1910.1200(e)(2))

"We will inform other employers (subcontractors) of precautionary measures and SDS access methods."
"Subcontractors must submit SDSs for their chemicals prior to mobilization."

Minute 8–10: The List and Training

You do not need to type the full chemical list into the policy document itself.

Write: "A list of hazardous chemicals is attached to this program and updated [Frequency]."
Write: "Training records are maintained [Location] and include employee names, dates, and topics covered."

Final Review

Print the document, sign it, and place it in the designated location.

The Audit Test: If an OSHA inspector asks a laborer, "Where is the HazCom program?", will they point to this document? If yes, you are compliant.

A written program is a living document. While this 10-minute draft gets you compliant today, the ongoing maintenance—updating the chemical list and training logs—keeps you safe tomorrow.