Written Hazard Communication Program for Contractors

A hazard communication (HazCom) program is the written program required by 29 CFR 1910.1200 for every employer whose workers may be exposed to hazardous chemicals, which on a construction site means nearly everyone: fuels, adhesives, solvents, concrete admixtures, paints, and compressed gases. The written program must cover your chemical inventory, how safety data sheets (SDS) stay accessible to the crew, how containers are labeled, and how employees are trained before their first exposure and when new hazards appear. HazCom is among the most cited OSHA standards every year.

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What the written program must contain

✓ A list of the hazardous chemicals known to be present, tied to their SDS
✓ How safety data sheets are maintained and kept readily accessible on site (a binder in the trailer or a phone-accessible system the crew can actually reach)
✓ Labeling: manufacturer labels stay on, and secondary containers get labeled when chemicals are transferred
✓ Employee information and training: hazards, protective measures, and how to read labels and SDS, before first exposure
✓ Multi-employer provisions: how you inform other contractors whose workers your chemicals could reach, and how you learn about theirs
✓ Who is responsible for keeping the inventory, sheets, and training current

Where contractors get cited

The citations are rarely exotic: no written program at all, SDS nobody can produce for the products in the gang box, unlabeled spray bottles of solvent, and no documented training. The unlabeled secondary container is the classic: acetone in a water bottle is a HazCom citation and a poisoning waiting to happen. A real program is mostly discipline: inventory what is on the truck, keep the sheets reachable, label everything, and train at hire.

Generate the written program

The TailgateDocs Written Safety Program ($149) includes a hazard communication section built for your trade’s actual chemical exposures, with SDS, labeling, and training procedures a small crew can run. Every citation is validated against a verified standards table before delivery.

Common questions

▸Does HazCom apply to construction?

Yes. 29 CFR 1926.59 applies the general industry hazard communication standard (1910.1200) to construction work, and OSHA cites construction employers under it constantly.

▸Do consumer products like store-bought cleaners count?

Consumer products used the way a normal consumer would use them (same duration and frequency) are exempt. A product used all day, every day, as part of the work typically is not.

▸Can SDS live on a phone instead of a paper binder?

Yes, if employees can actually access them at the site without barriers: known location, working device, no login they do not have. Many crews keep both a phone system and a trailer binder as backup.

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