Every organization must comply with HAZCOM, with a few limited exemptions and exclusions, such as EPA-regulated hazardous wastes being excluded. See the Guide to the California Hazard Communication Regulation.

Under HAZCOM regulations, employers must provide training on how to read labels and review safety data sheets for hazard information.2 You must have a safety data sheet for each hazardous chemical you use. Additionally, the standard contains:

• Specific criteria for classifying chemical hazards;
• Labeling provisions that include requirements for using standardized signal words, pictograms, hazard statements and precautionary statements;
• A specified format for safety data sheets (previously referred to as “Material Safety Data Sheets”);
• Specific definitions of terms used in the standard; and
• Information that must be included in employers’ written hazard communication program (discussed below).

Cal/OSHA’s HAZCOM standard can be found on the Department of Industrial relations website.

The Cleaning Product Right to Know Act requires manufacturers of designated cleaning products to disclose the chemicals in those products and create product safety data sheets.

Designated cleaning products include general cleaning, air care, automotive, or polish or floor maintenance products used primarily for janitorial, industrial or domestic cleaning purposes.

Employers with designated cleaning products in their workplaces must make those safety data sheets available to employees in the same way they would under HAZCOM.

In addition to the above required HAZCOM communications, Proposition 65 requires that employers with 10 or more employees warn any person prior to their exposure to a chemical known by the California government to cause cancer, birth defects or other reproductive harm.

Creating a Written HAZCOM Program

Use the Hazard Communication Program form to help you document the program.

You must explain how you will meet requirements for labeling hazardous substances and other forms of warning you will provide to employees.

You must obtain safety data sheets from manufacturers for all labeled containers and items on your hazardous substance inventory. Your suppliers must provide the safety data sheets, which contain information from a product’s manufacturer that describes the product’s chemical properties, potential hazards and safe handling instructions. Inspections are optional as long as you properly maintain all standard documents, such as safety data sheets, labels and warnings.

For each hazardous chemical in the workplace, you must maintain copies of the required safety data sheet and make sure they’re readily accessible to employees during their shifts. You can maintain them electronically if it does not create a barrier to immediate employee access.

All labels must have pictograms, a signal word, hazard and precautionary statements, the product identifier and supplier identification. Labels cannot be removed or defaced. A pictogram “quickcard” is currently available from OSHA.

• Hazard Communication Program

HAZCOM Training Requirements

Train all new employees. Provide refresher training when you receive new information on hazards and standards. New training is required whenever a new chemical hazard is introduced into the employees’ work area.

Employers also are required to provide training regarding new label elements and safety data sheet formats that result from revisions to federal and state HAZCOM regulations. See OSHA’s website for label contents and pictograms necessary for training, as well as answers to frequently asked questions regarding training.

An OSHA fact sheet https://www.osha.gov/publications/bytype/fact-sheets also has information on the minimum required topics for the training.

Further, employers should provide Proposition 65 warnings in the training. You can use the Initial Safety Training Certificate and Individual Safety Training Certificate forms to document training sessions.

• Initial Safety Training Certificate
• Individual Safety Training Certificate

HAZCOM Recording and Reporting

You must develop and maintain an inventory of all hazardous substances. Ensure that hazardous substances in the workplace have safety data sheets. You must document employee training and compliance with the standard.

1. 8 CCR sec. 5194

2. 8 CCR sec.5194