Hazard Communication: SDS, Labels, and Employee Right-to-Know Traps

29 CFR 1910.1200 · Hazard Communication Standard (HCS 2012 / GHS-aligned)

Keywords: hazard communication standard, SDS sections, GHS labels, pictograms OSHA, right-to-know training, signal words, chemical inventory, secondary container labeling

The 16 SDS Sections — Must-Know Numbers

GHS Label — 6 Required Elements

• Product identifier: chemical name or number
• Signal word: "Danger" (more severe) or "Warning" (less severe)
• Hazard statements: standardized phrases describing the nature of the hazard
• Precautionary statements: how to minimize or prevent exposure/injury
• Pictogram(s): GHS symbol in red diamond border
• Supplier identification: name, address, phone of manufacturer/importer

Exam Traps — HazCom

• Employees must be trained before their initial assignment to work with hazardous chemicals — not within 30 days of hire.
• Secondary containers (e.g., a smaller pour bottle) require labeling unless used by the same person during the same work shift and the contents are clear.
• SDSs must be readily accessible to employees during the work shift — locked in a filing cabinet does not meet the standard.
• The written HazCom program must list all hazardous chemicals in each work area — an SDS binder alone is not a substitute for the written program.
• "Warning" and "Danger" are not interchangeable. "Danger" = higher hazard category. Mixing them up is a common distractor.
• Employers must maintain SDSs for each chemical; they cannot simply reference the chemical manufacturer's website as the sole access method.

GHS Pictograms — What They Cover