Toxic and Hazardous Substances (1910 Subpart Z)

HazCom Is OSHA’s No. 2 Citation: How to Fix the Common Gaps

By Black Belt Safety Editorial Team 2 min read

Supervisor with a clipboard beside a shelf of labeled chemical bottles and drums
Image: Black Belt Safety

Hazard Communication is number 2 on OSHA’s preliminary Top 10 list of most cited standards for fiscal year 2026. The rule is 29 CFR 1910.1200. It applies to almost any workplace that has hazardous chemicals, from shops to job sites.

New to HazCom? Our Hazard Communication Basics course covers it in plain words. Our free HazCom guide explains the rule.

Gap 1: No written program

Employers must have a written hazard communication program. It lists the hazardous chemicals on site and says how labels, safety data sheets and training are handled.

Fix: Write it down, keep it current, and keep the chemical list matched to what is really on the shelf.

Gap 2: Safety data sheets missing or hard to reach

Safety data sheets (SDS) must be readily accessible to workers during each work shift while they are in their work area.

Fix: Keep a binder or an electronic SDS system that works without a password or a supervisor. Check that every product on the shelf has a sheet.

SDS binder on a bench next to two labeled spray bottles and one unlabeled bottle circled in red
Image: Black Belt Safety

Gap 3: Unlabeled containers

Shipped containers come with labels that show the product identifier, signal word, hazard statements, pictograms and precautionary statements. Trouble starts when a worker pours a chemical into a spray bottle or bucket with no label.

Fix: Label every workplace container with at least the product name and its hazards. Keep blank labels near where chemicals are poured.

Need your crew trained on labels and SDS? Our Hazard Communication Basics course covers labels, pictograms, SDS and your rights. It is part of The Dojo, our full course library.

Gap 4: No training, or training that is out of date

Workers must be trained on the hazardous chemicals in their work area at the time of their initial assignment, and whenever a new chemical hazard is brought in.

Fix: Train at hire, train again when a new product with a new hazard shows up, and keep a sign-in sheet.

Gap 5: Missing the 2024 update

OSHA updated the rule in 2024. Employers have deadlines to update workplace labels, the written program and training. See our post on the new HazCom compliance dates.

Close the gaps

Start the Hazard Communication Basics course or train your whole team.

About this post

This post is a plain-language aid, not a copy of the rule. Black Belt Safety is not part of OSHA. The regulation text is what counts.

Sources

HazCom Is OSHA’s No. 2 Citation: How to Fix the Common Gaps

Frequently asked questions

What is the most common HazCom citation?

Common gaps include no written program, missing SDS, unlabeled containers and missing training.

Where must safety data sheets be kept?

Where workers can readily get them during each work shift in their work area.

Do spray bottles need labels?

Workplace containers need a label with at least the product name and its hazards.

When is HazCom training required?

At initial assignment and whenever a new chemical hazard is brought into the work area.

Written and reviewed by

Black Belt Safety Editorial Team

Site Safety Officer and Safety Professional

OSHA 30 · CPR · USACE CQM

Written and reviewed by the Black Belt Safety team. Every post is checked against the OSHA standard or agency source it cites.

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