Chemical inventory: the list OSHA asks for, and the three jobs it does
OSHA's Hazard Communication Standard requires a list of every hazardous chemical known to be present in your workplace, named with the same product identifier the safety data sheet uses (29 CFR 1910.1200(e)(1)(i)). The list can cover the whole workplace or each work area, it belongs inside your written HazCom program, and every product on it needs an SDS on file. On a construction site, 29 CFR 1926.59 applies the same requirements.
Verified against the eCFR · September 26, 2026
At a glance
What the list must hold
Every hazardous chemical known to be present, by a product identifier that is referenced on its safety data sheet.
1910.1200(e)(1)(i)Scope
OSHA's workplace is “an establishment, job site, or project.” One list for the whole jobsite, or one per work area.
1910.1200(c), (e)(1)(i)Where it lives
Inside the written hazard communication program you keep at each workplace.
1910.1200(e)(1)The sheet behind each line
A safety data sheet in the workplace for each hazardous chemical you use.
1910.1200(g)(1)The 30-year record
An SDS showing a health hazard is an exposure record. Keep it, or keep the chemical's identity, where and when it was used, for 30 years.
1910.1020(d)(1)(ii)(B)EPA Tier II
At 10,000 lb on site at any one time (500 lb or the TPQ for extremely hazardous substances), the same list feeds a Tier II report due March 1.
40 CFR 370.10(a)What goes on a list that holds up
“A list of the hazardous chemicals known to be present using a product identifier that is referenced on the appropriate safety data sheet (the list may be compiled for the workplace as a whole or for individual work areas)”
OSHA names one column. The rest is what turns a list you keep for the inspector into a list that runs the site: it tells a worker where a product is, keeps the 30-year record for you, and answers Tier II.
| Column | Basis | Why it matters |
|---|---|---|
| Product identifier, spelled as on the SDS | 1910.1200(e)(1)(i) | Ties the list to the sheet and to the label. An inspector compares the three. |
| Manufacturer or supplier | Good practice | Two products with the same name are two different sheets. |
| Location: jobsite, work area, storage | (e)(1)(i); 1910.1020 | Tells a worker where the chemical is, and it is the “where” of the 30-year record. |
| Dates on site | 1910.1020(d)(1)(ii)(B) | The “when” of the 30-year record. |
| Largest amount on hand | 40 CFR 370.10(a) | Decides whether a site crosses a Tier II threshold. |
| SDS on file, with its revision date | 1910.1200(g)(1) | A missing sheet shows up on your list before it shows up in a citation. |
| Signal word and GHS pictograms | Good practice | Not required on the list, but it is what the workplace label shows ((f)(6)), so the crew sees the same hazards in both places. |
What the inspector checks on your list
OSHA's HazCom inspection directive, in force since May 19, 2026, tells the compliance officer what to look for under (e)(1)(i):
- “The inventory must have a product identifier for each chemical known to be present that aligns with the SDS and label.”
- “The inventory can be for the entire facility or for individual work areas.”
- “The inventory must include all chemicals present (even if the chemicals are stored/not in use).”
OSHA CPL 02-02-079 (HCS 2024), p. 33, read on the official PDF on September 26, 2026. The drum of form oil in the back of the connex counts, even if nobody has opened it this month.
How to build the list
Step 1
Walk every area with the containers in front of you
Storage trailer, gang boxes, trucks, the mechanical room. A list built from purchase orders misses what came in on a sub's truck.
Step 2
Write the product identifier exactly as the label spells it
OSHA wants the identifier that is referenced on the SDS (1910.1200(e)(1)(i)). Near-matches are how the list, the sheet and the label drift apart.
Step 3
Match every product to its sheet
Pull the SDS for each line (1910.1200(g)(1)). When a supplier hasn't sent one, request it in writing and keep the request.
Step 4
Record where it is and the most you keep on hand
The location answers the worker and the 30-year record. The quantity answers Tier II.
Step 5
Label every secondary container from the sheet
Product identifier plus the hazards, or the full shipped-label information (1910.1200(f)(6)).
Step 6
Keep it moving with the job
Add a product the day it arrives. When it leaves the site, retire the line with its date instead of deleting it: that date is part of the 30-year record.
Starting from a spreadsheet? The free template has every column above, and HazComFast imports it as is.
On a multi-employer jobsite
Every employer on the site owes its own crew the information on the hazardous chemicals they are exposed to (1910.1200(b)(1)), through its own written program and list. When one contractor's chemicals can reach another contractor's crew, OSHA adds three things to the program, and it names construction as the example:
“Employers who produce, use, or store hazardous chemicals at a workplace in such a way that the employees of other employer(s) may be exposed (for example, employees of a construction contractor working on-site) shall additionally ensure that the hazard communication programs developed and implemented under this paragraph (e) include the following”
- (e)(2)(i)
How the other employers get access to the SDS for each chemical their crews may be exposed to.
- (e)(2)(ii)
How you tell them the precautions for normal operations and foreseeable emergencies.
- (e)(2)(iii)
How you tell them about the labeling system used on the site.
A per-jobsite list makes those three answers fast: everyone can see what each trade brought, and each trade can see what it is working next to. More on the GC and subcontractor split on the subcontractors page.
One list, three jobs
Your HazCom program
The list is part of the written program OSHA asks for at each workplace. It is also the first page an inspector turns to, because every label and every sheet should trace back to a line on it.
1910.1200(e)(1)(i)The 30-year exposure record
An SDS indicating a health hazard is an employee exposure record. You may let the sheet go only if a record of the chemical's identity, where it was used and when it was used is kept for at least 30 years. OSHA counts “a chemical inventory or any other record which reveals where and when used and the identity” of a toxic substance as an exposure record in its own right. A dated inventory is exactly that record, and 1926.33 applies the same rules on a construction site.
1910.1020(c)(5)(iii)-(iv), (d)(1)(ii)(B); 1926.33EPA Tier II
At 10,000 lb of a hazardous chemical on site at any one time, or 500 lb or the threshold planning quantity of an extremely hazardous substance, the site owes a Tier II report by March 1 to the State Emergency Response Commission (SERC), Local Emergency Planning Committee (LEPC), Local fire department with jurisdiction over the facility. The quantities come straight off your list.
40 CFR 370.10(a), 40 CFR 370.45More on the EPA side: EPCRA Tier II reporting.
Storage: what HazCom does and doesn't cover
HazCom is labels, sheets and training
The Hazard Communication Standard doesn't set storage segregation rules. Flammable and combustible liquids are governed by 29 CFR 1926.152 (construction); 29 CFR 1910.106 (general industry). Keeping incompatibles apart is planned from SDS Section 7 (handling and storage) and Section 10 (stability and reactivity).
Labels on what you pour out
Every container in the workplace carries a label with the product identifier and its hazards (1910.1200(f)(6)). The one exception is a portable container filled from a labeled one for the immediate use of the worker who filled it (1910.1200(f)(8)). See workplace labels.
Run your inventory in HazComFast
The inventory is the center of HazComFast. The labels, the QR codes, the compatibility checks and the Tier II report all read from it, so you keep one list and everything else stays in step. The free plan runs one jobsite with up to 50 chemicals.
Scan the drum, get the sheet
Every line of the inventory prints its own QR code. Stick it on the container, and anyone on the crew scans it with the phone camera to open that product's hazard pictograms, its first-aid steps and the full sheet. No app to install, no account.
Built for jobsites where the signal drops
Your jobsite's SDS load onto the phone on their own. The app shows how many are ready (17 of 20, 20 of 20) before you head underground. First-aid steps for every product on the jobsite stay on the phone, even in airplane mode.
One list, everything in step
Add a product once. Its label, its QR code, its compatibility check and its Tier II quantity all come from that one record, so the list, the sheet and the label say the same thing when the inspector lines them up.
What each plan includes
- Chemical inventory by jobsiteFrom Free
- AI SDS extraction from your own PDFsFrom Free
- GHS workplace labels (Avery and Zebra stock)From Free
- QR codes and public container scanEvery plan
- Offline SDS packs, stored on the deviceFrom Free
- Storage compatibility checksFrom Free
- SDS revision-date monitoringFrom Starter
- Threshold alertsFrom Starter
- Tier II reportFrom Pro
- 30-year retention on exposure recordsEvery plan
- Full record export, any timeEvery plan
Key facts
- OSHA requires the list itself, not a format. A spreadsheet, a binder index or software all work, as long as every hazardous chemical present is on it by the identifier its SDS uses (1910.1200(e)(1)(i)).
- The written HazCom program is required at each workplace (1910.1200(e)(1)). A company-wide master list is useful, but each jobsite should be able to show what is actually there.
- An SDS indicating a health hazard is an employee exposure record (1910.1020(c)(5)(iii)). You can retire the sheet only if a record of the chemical's identity, where and when it was used is kept for 30 years.
- Tier II is EPA, not OSHA. It applies at 10,000 lb for a hazardous chemical present at any one time, or 500 lb or the threshold planning quantity, whichever is lower, for an extremely hazardous substance (40 CFR 370.10(a)).
- HazCom does not set storage segregation rules. Flammable and combustible liquid storage falls under 1926.152 on a construction site and 1910.106 in general industry.
- A portable container filled from a labeled container for the immediate use of the worker who filled it needs no label (1910.1200(f)(8)). Anything that sits overnight or changes hands does.
- Stored chemicals count. OSHA's 2026 inspection directive says the inventory “must include all chemicals present (even if the chemicals are stored/not in use)” (CPL 02-02-079, (e)(1)(i)).
- The HazCom Standard sets no update interval for the list. It has to be accurate for what is present, so it changes when the site does (1910.1200(e)(1)(i)).
Tools, guides and the standards
Free tools
- Chemical Inventory Template
The list, laid out for (e)(1)(i), Tier II and the 30-year record.
- SDS Gap Analyzer
Find the products with no sheet, or an old one.
- Chemical Compatibility Matrix
Check what can share a cabinet before it does.
- Tier II Threshold Screener
Does this site cross an EPA threshold?
- Tier II Builder
Draft the report from your inventory.
- Secondary Container Label Maker
Turn a list line into a workplace label.
In-depth guides
- The chemical inventory template that also covers Tier II
- Does every chemical need an SDS? The (b) exemptions
- 30-year record retention under 1910.1020
- Find the holes: an SDS library gap analysis
- Missing an SDS? Close the gap
- Does OSHA require separating incompatible chemicals?
- Preventing chemical reactions with a compatibility matrix
- EPCRA Tier II reporting for construction
Chemical inventory FAQ
Does OSHA require a chemical inventory list?
Yes. The written hazard communication program must include a list of the hazardous chemicals known to be present, using a product identifier that is referenced on the appropriate safety data sheet (29 CFR 1910.1200(e)(1)(i)). On construction sites, 29 CFR 1926.59 applies the same requirement.
What information has to be on the list?
OSHA requires the product identifier that matches the SDS. Everything else is what makes the list useful: manufacturer, location, dates on site, the largest amount on hand and whether the SDS is on file. Location and dates also serve the 30-year exposure record, and quantities serve EPA Tier II.
Can one list cover several jobsites?
OSHA defines a workplace as “an establishment, job site, or project, at one geographical location” (29 CFR 1910.1200(c)), and the written program, list included, is kept at each workplace ((e)(1)). A company master list is useful, but each jobsite needs a list of the chemicals actually present there, for the whole site or per work area.
Do chemicals in storage have to be on the list?
Yes. OSHA's HazCom inspection directive (CPL 02-02-079, 2026) says the inventory “must include all chemicals present (even if the chemicals are stored/not in use).” The list covers what is known to be present, not only what is in use today.
How often does the chemical inventory have to be updated?
The HazCom Standard sets no fixed interval. The list has to reflect the hazardous chemicals known to be present (29 CFR 1910.1200(e)(1)(i)), so it changes when a product arrives or leaves. Keep the dates: under 1910.1020 a record of identity, place and dates of use is what lets you retire old sheets.
Who keeps the list on a multi-employer jobsite?
Each employer owes its own employees information on the hazardous chemicals they are exposed to (29 CFR 1910.1200(b)(1)), through its own written program and list. When one employer's chemicals can expose another employer's crew, that employer's written program must also say how the other employers get SDS access, how they learn the precautions, and how they learn the labeling system (29 CFR 1910.1200(e)(2)).
How long do I have to keep the chemical inventory?
HazCom sets no retention period for the list. Under 29 CFR 1910.1020, an SDS showing a health hazard is an exposure record kept 30 years, unless you keep a record of the chemical's identity, where it was used and when it was used for 30 years instead (1910.1020(d)(1)(ii)(B)). A dated inventory is that record.
Is the chemical inventory the same as a Tier II report?
No, but it feeds it. Tier II is an EPA report under EPCRA section 312, due March 1 each year for the prior calendar year (40 CFR 370.45), when a hazardous chemical is present at or above 10,000 lb, or an extremely hazardous substance at or above 500 lb or its threshold planning quantity. It goes to the State Emergency Response Commission (SERC), Local Emergency Planning Committee (LEPC), Local fire department with jurisdiction over the facility.
Do consumer products belong on the list?
A consumer product is exempt when you can show it is used for the purpose its manufacturer intended, and that the duration and frequency of exposure are no greater than a consumer's (29 CFR 1910.1200(b)(6)(ix)). The same product used all day by a crew does not meet that test. When in doubt, list it and keep the sheet.
Sources
- ecfr.gov/current/title-29/section-1910.1200
- ecfr.gov/current/title-29/section-1926.59
- ecfr.gov/current/title-29/section-1910.1020
- ecfr.gov/current/title-29/section-1926.33
- ecfr.gov/current/title-40/part-370
- osha.gov/sites/default/files/enforcement/directives/CPL-02-02-079_0.pdf
29 CFR 1910.1200, 1910.1020 and 1926.33 read on the eCFR, and OSHA CPL 02-02-079 on its official PDF, on September 26, 2026. General guidance, not legal advice; OSHA-approved State Plans may impose additional requirements.
Get the Binder in Order Before the Inspector Arrives. Are You Ready?
OSHA does not give advance notice of inspections (29 CFR 1903.6). Get the binder in order before the opening conference, not during it.
Serious Violation
$16,550
per violation (max)
HazComFast Pro
$199/mo
10 jobsites, unlimited chemicals, unlimited workers
New sign-ups are paused. The free tools below need no account, and customers can log in as usual.
Your account keeps working as usual. Cancel anytime.