HazCom: Is Your Team Trained?

Are your employees exposed to hazardous chemicals? They might need HazCom training!

• By Rachel Krubsack
• Jun 30, 2025

If you have just ONE employee with the potential to be exposed to ONE non-exempt hazardous chemical, you must train that employee under paragraph (h) of 1910.1200. That’s OSHA’s Hazard Communication (HazCom) Standard. Obviously, by its very name, the standard is all about “communication.” Yet, some might argue that training is the keystone of the standard! Without proper training, the effectiveness of the other parts of HazCom may suffer.  

While your employees have a “right to know” about the chemical hazards in the workplace, they also have the “right to understand” chemical labels, safety data sheets (SDSs), and your written HazCom program. Once employees have that level of comprehension, it’s a safety (and health) culture shift. Your employees will be more likely to use control measures and wear their personal protective equipment (PPE). Chemical incidents and related costs may be prevented. 

OSHA Inspectors Will Ask Employees Questions 

If OSHA makes a visit, the compliance officer will interview your employees to determine whether they have an adequate grasp of chemical hazards they’re exposed to in the workplace. This may include questions such as: 

• Have you been trained on chemical hazards at work? 

• What are the health effects of that chemical you’re working with? 

• Your organization uses a labeling system. What does this label tell you? 

• Could you show me how you access an SDS? 

• What would you do in an emergency involving that chemical? 

If, based on these employee interviews, the officer determines that HazCom training wasn’t provided or was inadequate, you can be cited. Citations for training violations are generally considered to be “serious,” which means they carry a penalty of almost $16,600 per violation. If you have more than one violation, this figure can multiply. 

What’s Considered A Hazardous Chemical? 

The HazCom Standard defines a hazardous chemical as “any chemical which is classified as a physical hazard or a health hazard, a simple asphyxiant, combustible dust, or hazard not otherwise classified (HNOC).” These terms are defined in paragraph (c) of 1910.1200.  

A physical hazard or health hazard may pose any of the hazardous effects listed in Table 1, “Hazardous Effects.” 

Table 1: Hazardous Effects 

The standard contains 12 exemptions in paragraph (b)(6) which may apply to your situation. Often employers can spot an exemption for some of their hazardous chemicals, so it’s worth checking the list. Consumer products, for instance, are exempt if they’re only used at work as intended by the manufacturer or importer and that use is in a duration and frequency no greater than the range a consumer would reasonably experience. 

In many cases, OSHA lists a substance as exempt at paragraph (b)(6) because it’s regulated by another OSHA standard or another federal agency. Hazardous waste covered under EPA’s Resource Conservation and Recovery Act (RCRA), is an example. 

If your operations and your chemicals are not entirely exempted, and you’re left with some covered hazardous chemicals that your employees are potentially exposed to during normal operating conditions or in a foreseeable emergency, you must provide training to those employees.  

What Must Be Covered in Training? 

Employees must be trained at the time they’re assigned to work with a hazardous chemical AND whenever a new chemical hazard is introduced into the work area. If you have few chemicals in the workplace and they don’t change often, training on individual chemicals may be the easiest approach. On the other hand, if you have many chemicals or frequent changes to chemicals, you may prefer to train based on chemical hazard categories, such as flammability and corrosivity. 

Information and training must include: 

• The general requirements of the HazCom Standard. Essentially, the standard says that information about chemical hazards must be passed downstream from the manufacturer, importer, or distributor to the employer, who then shares it with employees who are exposed to these hazards. This information is in the form of labels and SDSs. You, as an employer, must communicate information concerning hazards and appropriate protective measures to employees through training. Your written program also offers a chemical inventory and dictates how you’ll comply. 

• Operations in employees’ work area where they may be exposed to chemicals. 

• The location and availability of your written HazCom program, chemical inventory, and SDSs. 

• How to detect the presence or release of a hazardous chemical in the work area, such as employer monitoring or the visual appearance or odor of hazardous chemicals when released. 

• The physical and health hazards of the chemicals in the work area.  

• How your employees can protect themselves from these hazards, such as with work practices, emergency procedures, and PPE. 

• The details of your written HazCom program (including the chemical inventory), SDSs, and an explanation of labels received on shipped containers and any labeling system used in the workplace. 

If you have employees who do special, non-routine tasks (like tank clean outs) that may expose them to hazardous chemicals, you must inform them about those chemicals’ hazards. You should also inform them about how to control exposure and what to do in an emergency. Be sure to evaluate the hazards of these tasks and provide appropriate controls including PPE and any additional training as required.  

Finally, you also must inform employees of the hazards associated with chemicals contained in unlabeled pipes in their work areas. 

Note, in multi-employer worksites, you are responsible for providing updated training when your employees are exposed to new hazards, even if these hazards are created by other employers. 

No formal certification is required for a person to train in HazCom. You, the employer, determine who’s qualified to do training. That may be someone within your organization or a third party. OSHA expects that the trainer has the knowledge and understanding to present the information and training elements so that they’re clear to all employees and that it’s specific to the workplace. 

The trainer must be familiar with the: 

• Requirements of the HazCom Standard as applied to your workplace; 

• Hazardous chemicals in the workplace to which workers are potentially exposed, as well as the types of hazards they pose; 

• Written HazCom program implemented in the workplace; and 

• Measures being used to protect employees. 

Training Effectiveness 

OSHA requires that “effective” training be provided. In other words, the training program must give employees the information they need, and they must be able to carry that knowledge into their daily jobs.  

Any means of presenting the material are acceptable, such as classroom or online training. However, OSHA cautions that you must cover worksite-specific information like the chemicals that are present, the details of your written HazCom program, the location of SDSs, and the labeling system used in the workplace. Employees also must have the opportunity to ask questions and receive answers in a timely manner. 

You’re not required to give a quiz or test after training, but that can be a great way to check in with employees and see if they understand the material. Another assessment tool is observing employee behavior after training. This lets you see if they’re putting into practice what they learned and are working safely when using chemicals. You may consider asking your employees questions, as an OSHA compliance officer would. 

It's a best practice to provide annual training, although the HazCom Standard doesn’t require it. Refresher training too is not required, but if employees aren’t exercising skills they should have learned during training, it’s time to revisit training. The good news is you may not need to repeat your entire training program but focus instead on the area of concern, like labels or SDSs. 

Key to remember

If you have even ONE employee who is potentially exposed to ONE non-exempt hazardous chemical, you’re covered by the HazCom Standard and must provide training as outlined in 1910.1200(h). 

This article originally appeared in the June 2025 issue of Occupational Health & Safety.