OSHA 1910.1200 and GHS Revisions: A Step-by-Step HazCom Guide

Frequently Asked Questions

What should I review first when updating my HazCom program for OSHA 1910.1200 and GHS revisions?

Start by comparing your current written Hazard Communication program to the chemicals and tasks actually present on site. Most facilities should first review their written program, chemical inventory, labels, SDS access, training materials, contractor communication, and purchasing workflows.

Why should I verify my chemical inventory before updating labels or training?

If your inventory is incomplete, you cannot reliably manage SDSs, labels, storage, or employee training. A physical verification often uncovers outdated SDSs, duplicate products, unknown materials, and unlabeled secondary containers that need follow-up first.

What label and SDS issues should I check at my facility?

Check that labels include the required elements and that employees can identify hazards during routine work, maintenance, cleaning, and spill response. For SDSs, make sure every hazardous chemical has one, access works on every shift, backup access exists during outages or emergencies, and old versions are controlled.

How should I train employees on HazCom changes?

Use short, task-based training tied to the chemicals employees actually use rather than only classroom slides. Workers should know where chemicals are present, how to read labels, how to find SDSs, what protective measures apply, and how to report spills, leaks, or exposures.

How do I keep HazCom current after the initial update?

Build HazCom checks into purchasing, change management, contractor onboarding, and routine audits so chemical communication stays current as operations change. Field audits should confirm labels are in place, SDS access works, employees understand the information, and corrected issues stay fixed.