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.

OSHA's written-program rule (1910.1200(e)(1)) is short — it wants your plan to describe how you meet three things: labeling and other forms of warning, SDS maintenance and access, and employee information and training — plus a list of the hazardous chemicals known to be present. Every phase below maps to one of those. (Construction employers are covered identically through 29 CFR 1926.59.)

A written OSHA HazCom program is required under 29 CFR 1910.1200(e) and must describe how you meet the labeling, safety-data-sheet, and training requirements plus a list of hazardous chemicals — it can be drafted in about ten minutes by focusing on those mandatory elements and tailoring them to your site.

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). The employer stays responsible for compliance; this is the person who keeps the program current.
• 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." (Workplace labels follow 1910.1200(f)(6): either the shipped-label elements, or the product identifier plus at least general information on the hazards.)

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." OSHA's HCS directive (CPL 02-02-079) expects a backup when SDSs are kept electronically, because 1910.1200(g)(8) requires them to be readily accessible during each work shift.

Minute 6–8: The "Construction Clauses"

These are the two clauses a construction site cannot skip, because 1910.1200(e)(1)(ii) and (e)(2) name them outright.

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." 1910.1200(e)(1)(ii) also asks how you inform employees of the hazards of chemicals in unlabeled pipes in their work areas; pipes are not containers under 1910.1200(c), so the program, not a label, carries that information.

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

• "We will inform other employers (subcontractors) of precautionary measures, SDS access methods, and our labeling system." (1910.1200(e)(2)(i)-(iii) lists those three.)
• "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." HazCom itself requires no training record, but the record is how you show the training of 1910.1200(h) happened.

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 have passed one of the first checks; compliance still depends on the labels, SDSs, and training working the way the program says.

A written program is a living document. The 10-minute draft gives you the structure; the ongoing maintenance, updating the chemical list and the training, keeps it true.

What 1910.1200(e) Asks For, Line by Line

The whole requirement fits on one screen, which is why ten minutes is realistic:

• (e)(1): a written program, kept at each workplace, that describes how you meet the labeling (f), SDS (g), and training (h) requirements.
• (e)(1)(i): a list of the hazardous chemicals known to be present, using the product identifier on each SDS; one list for the site or one per work area.
• (e)(1)(ii): how you inform employees of the hazards of non-routine tasks and of chemicals in unlabeled pipes.
• (e)(2)(i)-(iii): on multi-employer sites, how other employers get SDS access, learn your precautionary measures, and learn your labeling system.
• (e)(3): you may rely on an existing program if it meets these criteria.
• (e)(4): the program is available on request to employees, their designated representatives, and OSHA.
• (e)(5): crews that travel between sites during a shift may have the program kept at the primary workplace facility.

For HCS 2024, the program needs updating for substances by November 20, 2026 (1910.1200(j)(2)(ii)); until then, 1910.1200(j)(4) lets you comply with either the current or the 2012 version of the standard.

The standard, tools & related reading

• The standard: Hazard Communication — 29 CFR 1910.1200 (construction via 1926.59)
• Build it fast: HazCom Program Generator · Chemical Inventory Template · HazCom Training Record
• Related guides: Complete OSHA HazCom 2026 Guide · 2026 HazCom Compliance Audit (Nov 20) · Ultimate Chemical Inventory Template
• 2026 OSHA penalty schedule · penalties by state