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Free PDF · no email · Dirty-Dozen-HazCom-Violations.pdf

The Dirty Dozen: 12 HazCom Violations to Prevent

Twelve Hazard Communication violations an employer can prevent, each tied to its paragraph of 29 CFR 1910.1200 and to the maximum penalty of 29 CFR 1903.15(d): up to $16,550 per serious violation and $165,514 per willful or repeated one. It is a checklist, not a ranking.

The full document

#ViolationRuleMaximumFix
01No written Hazard Communication Program29 CFR 1910.1200(e)Up to $16,550Create and maintain a written program.
02Safety Data Sheets not readily accessible29 CFR 1910.1200(g)Up to $16,550Keep SDSs readily accessible in the work area during each shift.
03Unlabeled / mislabeled secondary containers29 CFR 1910.1200(f)(6)Up to $16,550Label all containers with product ID and hazards.
04No employee training on chemical hazards29 CFR 1910.1200(h)Up to $16,550Train at initial assignment and when a new chemical hazard is introduced.
05Missing or outdated SDSs in the binder29 CFR 1910.1200(g)Up to $16,550Obtain current SDSs. Software flags the ones that go missing or out of date.
06Non-routine task hazards not communicated29 CFR 1910.1200(e)(1)(ii)Up to $16,550Document and brief hazards before the task.
07Multi-employer site: no coordination with subs29 CFR 1910.1200(e)(2)Up to $16,550Exchange hazard info. Verify sub compliance.
08Physical binder lost, damaged, or off site29 CFR 1910.1200(g)(8)Up to $16,550Digital SDS: the jobsite's SDS on every phone, a QR code on each container, a printed set as backup.
09No chemical inventory or outdated inventory29 CFR 1910.1200(e)(1)(i)Up to $16,550Maintain a current inventory linked to SDSs.
10GHS labels not updated for Rev 729 CFR 1910.1200(f)Up to $16,550Update labels per GHS Rev 7. Check supplier SDSs.
11Training workers cannot understand29 CFR 1910.1200(h)(1)Up to $16,550Train in a language and vocabulary workers understand; records are good practice.
12Willful / repeat after citation29 CFR 1903.15Up to $165,514Correct all items. Show proof. Prevent recurrence.

Questions about this document

Is this a ranking of the most-cited HazCom violations?

No. It is a checklist of twelve violations to prevent. OSHA's FY2025 Top 10 ranks the Hazard Communication standard, 29 CFR 1910.1200, second overall, but OSHA publishes no ranking of its paragraphs.

How much can one HazCom violation cost?

Up to $16,550 per serious violation and $165,514 per willful or repeated violation (29 CFR 1903.15(d)). The amount OSHA proposes depends on gravity, size, good faith, and history (29 CFR 1903.15(b)).

Does HazCom require refresher training every year?

No. 29 CFR 1910.1200(h)(1) requires training at initial assignment and whenever a new chemical hazard the employees have not been trained about is introduced into their work area; it sets no annual interval.

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)

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