Hazard communication (29 CFR 1910.1200): SDS, labels, training and incident records
Short answer
The Hazard Communication Standard requires a written program, labels and worker training. It also requires a safety data sheet (SDS) for each hazardous chemical, readily accessible every shift. It applies wherever workers may be exposed to a hazardous chemical. Revised provisions have staged compliance dates from May 19, 2026 to May 19, 2028.
- Standard
- 29 CFR 1910.1200, Hazard communication
- Core duties
- Written program, labels, safety data sheets, training
- Revised rule
- Published 2024-05-20 (89 FR 44144), effective 2024-07-19
- Extension
- Compliance dates moved four months by 91 FR 1695 (2026-01-15)
- Next employer date
- 2026-11-20 for substances; 2028-05-19 for mixtures
- Exposure records
- At least 30 years under 1910.1020
- Enforcement
- Second most frequently cited standard in fiscal year 2025
Applies to: Employers with hazardous chemicals in the workplace, including manufacturers, laboratories, warehouses, utilities, chemical and food processors, and healthcare facilities · Chemical manufacturers, importers and distributors, who also classify hazards and prepare labels and safety data sheets · Construction employers, through 29 CFR 1926.59
What must employers do?
Four duties apply: a written program, labels, safety data sheets (SDSs) and training. They cover any chemical known to be present where workers may be exposed in normal use or a foreseeable emergency (1910.1200(b)(2)). If you do not make or import chemicals, focus on the program and worker information.
| Duty | What it asks | Paragraph |
|---|---|---|
| Written program | Kept at each workplace. Lists hazardous chemicals by a product identifier shown on the SDS. Says how you will inform workers of non-routine task hazards and chemicals in unlabeled pipes. | (e) |
| Labels | Shipped containers need a product identifier, signal word, hazard and precautionary statements, pictograms and supplier details. Workplace containers need the same. Or they need a product identifier plus words, pictures or symbols giving general hazard information. Leave incoming labels on. Portable containers for immediate use by the person who filled them are exempt. | (f) |
| Safety data sheets | One SDS for each hazardous chemical used, readily accessible in the work area each shift. Electronic access is allowed if it creates no barrier to immediate access. | (g)(1), (g)(8) |
| Training | At initial assignment and whenever a new chemical hazard is introduced. Covers detecting releases, hazards, protective measures, and reading labels and SDSs. | (h) |
Which SDS sections matter in an incident?
An SDS has sixteen sections in a fixed order (1910.1200(g)(2)). OSHA does not enforce sections 12 to 15. Early sections cover identification, hazards, composition, first aid, fire-fighting, spills, handling and exposure controls. Later ones cover physical properties, toxicology, ecology, disposal, transport, regulatory information and the revision date.
- Section 4, first-aid measures: what to do for exposure, and what to tell the clinician.
- Section 6, accidental release measures: spill response and containment.
- Section 8, exposure controls and personal protection: the protective equipment and controls to use.
- If a shipment arrives without an SDS, get one as soon as possible. If you prepare an SDS, add significant new hazard information within three months ((g)(6)(iii), (g)(5)).
What are the 2026 to 2028 compliance dates?
A rule published January 15, 2026 (91 FR 1695) moved each compliance date of the revised standard back four months. As of October 2026, the first date has passed. November 20, 2026 is next.
| Date | Who | What |
|---|---|---|
| May 19, 2026 | Manufacturers, importers and distributors evaluating substances | Comply with all modified provisions |
| November 20, 2026 | Employers, for substances | Update alternative workplace labeling, the program and training for newly identified hazards |
| November 19, 2027 | Manufacturers, importers and distributors evaluating mixtures | Comply with all modified provisions |
| May 19, 2028 | Employers, for mixtures | Same updates as above |
Until those dates, you may follow the current text, 1910.1200 as revised July 1, 2023, or both (1910.1200(j)(4)).
What to document after an exposure or spill
The standard has no incident report form. These are practice suggestions. An exposure or spill tests your labels, SDSs and training, so record how each performed.
| Capture | Why it matters |
|---|---|
| Product identifier and SDS version in use | Links the event to SDS sections 4, 6 and 8 |
| Container and label status: shipped label, workplace label, secondary container, unlabeled pipe | A missing or unclear label is a finding under (f) and (e)(1)(ii) |
| Task, routine or non-routine | Non-routine tasks need hazard information in the program |
| Who was exposed, how long, what symptoms | Drives recordability and any severe injury report |
| Controls in use: ventilation, protective equipment, first aid given | Compare with SDS section 8 and the first aid versus medical treatment line |
| Air or biological monitoring results | Employee exposure records, kept a long time |
| Training of those involved and any exposed contractor workers | Tests (h) and the multi-employer duties in (e)(2) |
How long must exposure and incident records be kept?
OSHA 300 records are kept five years. Exposure records are kept at least thirty.
| Record | Retention | Source |
|---|---|---|
| OSHA 300 Log, privacy case list, 300A and 301 | 5 years after the year covered | 1904.33 |
| Employee exposure records, including monitoring results | At least 30 years. Lab worksheets can go after 1 year, but keep results, sampling plan and methods 30 years | 1910.1020(d)(1)(ii) |
| SDSs for chemicals no longer in use | No set period. Keep a record of the chemical's identity and where and when it was used for 30 years | 1910.1020(d)(1)(ii)(B) |
| Employee medical records | Employment plus 30 years. Exceptions include minor on-site first aid records kept separately | 1910.1020(d)(1)(i) |
| SDSs for chemicals in current use | Keep in the workplace and readily accessible | 1910.1200(g)(8) |
A chemical incident can also be a Part 1904 case. If it causes a death, in-patient hospitalization, amputation or eye loss, it is also a severe injury report. Release-prevention rules for covered processes are in process safety incident investigation.
Does it apply in construction, laboratories and warehouses?
Yes, with variations for each setting.
| Setting | What applies |
|---|---|
| Construction | 1926.59 says construction requirements are identical to 1910.1200 |
| Laboratories | Partial: keep incoming labels intact. Keep the SDSs you receive and give access. Give information and training. Training need not cover where the written program is kept. |
| Sealed containers (warehousing, retail, marine cargo) | Partial: do not remove or deface labels. Keep SDS copies accessible. Train as needed for a spill or leak. |
| Multi-employer workplaces | Your program says how other employers' workers reach SDSs and learn the precautions and labeling system |
How IncidentKit supports this requirement
| What the rule asks for | Where it lives in IncidentKit |
|---|---|
| A safety data sheet for each hazardous chemical, readily accessible each shift ((g)(8)) | IncidentKit runs alongside your SDS and EHS systems and does not host your SDS library. Attach SDS pages and label photos as evidence. |
| Train workers on hazards and protective measures ((h)) | Investigations record contributing factors, so a training or labeling gap counts as a cause. |
| Document exposure and spill incidents | One record covers every incident type. Lauren asks what chemical, where, who was exposed and what was done. Drafted fields read 'Lauren · draft' until a person approves them. |
| Fix labeling, program and training gaps found | Corrective actions have an owner, due date, evidence and an effectiveness check before closing. |
| Record and report resulting injuries | OSHA 300, 300A and 301 exports and automated reportability rules are rolling out. Types that start a reporting clock flag the deadline. |
Product parts involved: Incident reporting, Lauren, the AI assistant, Investigations and RCA, Corrective actions (CAPA), Analytics. Capabilities marked “rolling out” are being released in stages; see the changelog.
Frequently asked questions
Do I have to label a secondary container?
Usually yes, with a workplace label. A portable container is exempt if the person who filled it from a labeled container uses it right away.
When must workers be trained on hazardous chemicals?
At initial assignment, and whenever a new chemical hazard is introduced into their work area. Training covers detecting a release, the hazards, protective measures, and using labels and SDSs. Labels and SDSs must always make chemical-specific information available.
Is a chemical spill reportable to OSHA?
Only through the severe injury rule: a work-related death, in-patient hospitalization, amputation or loss of an eye, on the 8-hour and 24-hour clocks. The standard has no spill report. Check environmental release rules too.
What does the 2026 extension change?
It moved each compliance date back four months, to May 19, 2026, November 20, 2026, November 19, 2027 and May 19, 2028. Until then, you may follow the revised text or the July 2023 version.
Sources
- eCFR: 29 CFR 1910.1200, Hazard communication (current through 2026-10-01)
- Federal Register: Hazard Communication Standard, compliance date extension (91 FR 1695, 2026-01-15)
- Federal Register: Hazard Communication Standard final rule (89 FR 44144, 2024-05-20)
- OSHA: Hazard communication topic page
- eCFR: 29 CFR 1910.1020, Access to employee exposure and medical records
- OSHA: 29 CFR 1926.59, Hazard communication (construction)
- OSHA: Top 10 most frequently cited standards, fiscal year 2025
Reviewed against the sources above on Oct 5, 2026. Rules change: confirm current requirements with the issuing body or your counsel before relying on any summary.
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