Every construction site uses chemicals: paints, solvents, adhesives, sealers, concrete accelerators, welding supplies, cleaning products, and fuels. But here’s the problem: Many workers don’t know what chemicals they’re handling or what health risks they pose. OSHA’s Hazard Communication Standard (HazCom or HCS) gives workers the “right to know” about the chemicals they work with. It’s been the #2 most cited OSHA violation for years, with 2,546 citations in 2025 alone. This guide explains what OSHA requires, what workers need to know, and how to implement a HazCom program that actually protects people.
What Is OSHA Hazard Communication (HazCom)?
OSHA’s Hazard Communication Standard (1910.1200 for general industry, 1926.59 for construction) requires that:
- Chemical manufacturers and importers evaluate and label hazardous chemicals
- Employers provide information about chemicals to their workers
- Workers are trained to understand hazards and work safely with chemicals The core principle: Workers have the right to understand what chemicals they’re exposed to and how to protect themselves.
The Three Pillars of HazCom
Pillar 1: Labels
Labels on chemical containers must clearly identify:
- Chemical name (or product name)
- Hazard classification (health hazard, fire hazard, environmental hazard, etc.)
- Signal word (“Danger” for serious hazards, “Warning” for less serious)
- Hazard statements (e.g., “Causes respiratory irritation”)
- Precautionary statements (e.g., “Use in well-ventilated area”)
- Manufacturer name and contact info OSHA requirement: Every chemical container must have a label, even in-house transfer containers. Common violations:
- Blank or faded labels
- Containers with no labels
- Labels not in workers’ language
Pillar 2: Safety Data Sheets (SDS)
An SDS (Safety Data Sheet) is a detailed document about a chemical’s hazards, safe handling, and emergency procedures. SDS must be available for every hazardous chemical on-site in accessible format (physical copies or electronic access). Required sections (16-section GHS format):
- Identification (chemical name, manufacturer)
- Hazard identification (what are the dangers?)
- Composition/Information on ingredients
- First-aid measures (what if exposed?)
- Fire-fighting measures
- Accidental release measures
- Handling and storage (safe practices)
- Exposure controls/PPE (what protection needed?)
- Physical and chemical properties
- Stability and reactivity
- Toxicological information (health effects)
- Ecological information
- Disposal considerations
- Transport information
- Regulatory information
- Other information Key sections for workers:
- Section 2 (Hazard identification): What are the dangers?
- Section 3 (Composition): What chemicals are in it?
- Section 4 (First-aid): What if I’m exposed?
- Section 8 (Exposure controls/PPE): What gear do I need?
- Section 16 (Other): Additional safety info Common violations:
- Missing SDS for chemicals on-site
- SDS not accessible (locked in a cabinet, only supervisor has access)
- Outdated SDS (not updated when chemical formulas change)
Pillar 3: Worker Training
Employers must train workers before they’re exposed to hazardous chemicals and whenever new chemicals are introduced. Training must cover:
- How to read labels and recognize hazard symbols
- Where SDS documents are and how to access them
- What chemicals are in their work area
- How they might be exposed (breathing, skin contact, ingestion)
- What health effects can occur (acute vs. chronic)
- Safe handling procedures for chemicals they use
- Required PPE (gloves, respirators, goggles, etc.)
- What to do if exposed (first aid, calling 911)
- Emergency procedures (spill response, evacuation) Common violations:
- No documented training for workers
- Training given verbally with no record
- Training doesn’t cover all chemicals on-site
Common Hazardous Chemicals on Construction Sites
Paints, Stains, and Coatings
Hazards: Volatile organic compounds (VOCs) cause respiratory irritation, dizziness, headaches. Some are flammable. Exposure route: Inhalation, skin contact PPE: Gloves, respirator (if airborne), eye protection First aid: If inhaled, move to fresh air. If skin contact, wash with soap and water.
Solvents (Paint Thinners, Degreasers)
Hazards: Flammable, can cause respiratory and nervous system effects. High vapor pressure. Exposure route: Inhalation, skin contact PPE: Gloves, respirator, eye protection; work in ventilated area First aid: Move to fresh air if inhaled; wash skin thoroughly.
Adhesives (Construction Adhesives, Epoxy)
Hazards: Can cause respiratory irritation, skin sensitization, eye damage. Some contain hazardous isocyanates. Exposure route: Inhalation, skin contact, eye contact PPE: Gloves, respirator, safety glasses First aid: Wash skin immediately; flush eyes with water for 15+ minutes if contact.
Concrete Accelerators & Curing Compounds
Hazards: Contain calcium chloride or sodium chloride; can cause eye/skin irritation. Some are corrosive. Exposure route: Skin/eye contact, inhalation of dust PPE: Gloves, eye protection, dust mask if powder form First aid: Rinse skin/eyes with water for 15 minutes.
Silica Dust (Concrete Cutting, Grinding)
Hazards: Causes silicosis (lung disease) with chronic exposure. Classified as a carcinogen. Exposure route: Inhalation PPE: Respirator (P100 or PAPR), respiratory protection required First aid: Remove from dusty area; monitor for respiratory symptoms.
Welding Fumes
Hazards: Contain manganese, hexavalent chromium (Cr+6), and other metals. Cause respiratory disease and neurological effects. Exposure route: Inhalation PPE: Respirator with appropriate cartridge, local exhaust ventilation First aid: Move to fresh air; monitor for respiratory symptoms.
Pesticides (if used on-site)
Hazards: Vary widely; can be acutely toxic or cause chronic health effects. Exposure route: Inhalation, skin contact, ingestion PPE: Depends on product; refer to SDS First aid: Follow SDS instructions; call Poison Control if ingested.
How to Implement a HazCom Program
Step 1: Identify All Hazardous Chemicals On-Site
Create an inventory of every chemical used: paints, solvents, adhesives, fuels, cleaning products, etc. Include:
- Product name
- Manufacturer
- Form (liquid, powder, aerosol)
- Use/location
- Quantity
Step 2: Obtain Labels & SDS
For each chemical, ensure:
- Label is complete and readable (not faded or worn)
- SDS is current (manufacturers update SDSs; use most recent version)
- Both are in workers’ language (Spanish, etc., if needed) Where to get SDS:
- Manufacturer website (usually downloadable PDF)
- Supplier sends with delivery
- Safety.com, MSDS databases (if lost)
Step 3: Organize & Access System
Make labels and SDS accessible to all workers: Physical copies:
- Binder with SDS for all chemicals, kept on-site
- Located near where chemicals are used
- Clearly labeled: “Safety Data Sheets”
- Include a list of all chemicals Electronic access:
- Database or cloud storage (e.g., Google Drive) accessible from site
- Link to manufacturer SDS online
- Ensure workers can access during work (phone/tablet access)
Step 4: Train All Workers
Conduct training covering:
- How to read labels (hazard symbols, signal words)
- How to access and read SDS documents
- Hazards of chemicals they use
- Safe handling procedures
- Required PPE
- Exposure control measures
- What to do if exposed
- Emergency response (spill, accidental exposure) Document training:
- Keep a training log (who, when, what covered)
- Have workers sign off
- Retrain when new chemicals introduced
Step 5: Update & Maintain
- Remove old chemicals from inventory
- Update SDS when new versions released
- Add new chemicals to list when introduced
- Conduct periodic refresher training
HazCom Compliance Checklist
Use this to audit your HazCom program:
- [ ] Written HazCom program in place (documented, available to workers)
- [ ] Complete inventory of all hazardous chemicals on-site
- [ ] All chemical containers labeled with:
- [ ] Product name
- [ ] Hazard classification
- [ ] Signal word
- [ ] Hazard statements
- [ ] Precautionary statements
- [ ] Manufacturer name/contact
- [ ] SDS available for all chemicals:
- [ ] Current/up-to-date (not expired/outdated)
- [ ] Accessible to all workers (not locked away)
- [ ] In workers’ language (if non-English speakers on-site)
- [ ] All workers trained on HazCom:
- [ ] Before initial assignment to area with hazardous chemicals
- [ ] When new chemicals introduced
- [ ] Training documented (names, dates, topics)
- [ ] Training covers:
- [ ] How to read labels
- [ ] How to access and read SDS
- [ ] Hazards of specific chemicals used
- [ ] Safe handling procedures
- [ ] Required PPE
- [ ] Exposure controls
- [ ] First-aid procedures
- [ ] Emergency response
- [ ] Non-routine tasks** briefed on HazCom:
- [ ] Workers assigned to different areas trained on those chemicals
- [ ] Temporary workers trained before assignment
- [ ] Contractors informed of hazardous chemicals on-site
Real-World Example: HazCom in Action
Scenario: Commercial Paint Job
Site: 5-story office building, interior painting. Chemicals on-site:
- Latex paint (2 colors)
- Oil-based primer
- Paint thinner
- Caulk and adhesive
- Silicone sealant
- Drywall compound OSHA HazCom Requirements:
- Label: Each paint can, primer container, and thinner jug has labels identifying hazards.
- SDS: Safety Data Sheets for all 6 products in a binder on-site.
- Training: All painters trained before work:
- How to read labels (hazard symbols, signal words)
- Access to SDS documents
- Hazards: VOCs cause respiratory irritation; some products flammable
- Safe practices: Use in ventilated area, avoid skin contact
- PPE: Gloves, eye protection, respirator if fumes heavy
- Spill response: Contain spill, ventilate, dispose per SDS
- First aid: Wash skin; flush eyes with water if contact Result: Workers understand what they’re using, risks, and how to protect themselves. OSHA inspection finds compliant HazCom program.
FAQ
- Do workers need to understand the SDS? Or just know it exists?
- Workers must be trained on how to access and understand the SDS. They should be able to look up a chemical and find key information (hazards, required PPE, first-aid).
- What if a chemical isn’t labeled hazardous? Do I still need an SDS?
- If it’s a standard consumer product (e.g., off-the-shelf glass cleaner), HazCom doesn’t apply. However, industrial products (paints, solvents, adhesives) typically are hazardous and require labels and SDS.
- How often do I need to retrain workers on HazCom?
OSHA doesn’t specify a frequency. However, retrain whenever:
- New chemicals are introduced
- Work procedures change (e.g., switch from brush to spray application)
- Workers transfer to new areas with different chemicals
- New workers are hired
- Can I share an SDS in a group email instead of printing it?
- Yes, as long as workers have continuous access. Email is sufficient if workers can reliably retrieve and read it. Printing and posting is more practical for on-site reference.
- What if a chemical doesn’t have an SDS?
- Don’t use it. All hazardous chemicals must have an SDS. If the manufacturer doesn’t provide one, contact the supplier or manufacturer before using the product.