If your workers can be exposed to hazardous chemicals — and in most trades they can, from adhesives and solvents to fuels and cleaning agents — OSHA's Hazard Communication standard requires you to have a written program. It's one of the most broadly applicable requirements OSHA has, and one of the most frequently cited when it's missing or thin.
A HazCom program generally has to address:
Container labeling — how hazardous chemicals in your workplace are labeled, including the standardized elements the standard requires and how you handle secondary containers.
Safety Data Sheets (SDS) — how you obtain, maintain, and give employees ready access to the SDS for every hazardous chemical on site.
Employee training — how workers learn about the hazards, how to read labels and SDS, and how to protect themselves.
A written chemical inventory — the list tying it all together.
The GHS Revision 7 update most programs haven't caught up to
OSHA updated the Hazard Communication standard in 2024 to align with Revision 7 of the Globally Harmonized System. That changed specifics in how hazards are classified and how labels and safety data sheets have to be presented. A HazCom program written before that update — or copied from an older template — can be out of step with the current requirement. Being current here is exactly the kind of detail a prequalification reviewer or inspector notices.