Hazardous Materials Safety Guide
HAZMAT Safety: OSHA HazCom, GHS, and Emergency Response
A comprehensive guide to hazardous materials regulations for New Jersey employers — covering HazCom 2012, GHS labeling, SDS requirements, employee training, spill response, and DOT transport compliance.
Hazardous materials are present in virtually every workplace — from cleaning chemicals in an office to industrial solvents on a factory floor. OSHA's Hazard Communication Standard (HazCom 2012, 29 CFR 1910.1200) aligns with the Globally Harmonized System (GHS) and requires employers to identify chemical hazards, maintain Safety Data Sheets, label containers properly, and train workers before they are exposed. Failure to comply is consistently among OSHA's top-ten most-cited violations — and the consequences of a chemical incident without a trained workforce can be catastrophic. This guide covers what OSHA requires, how GHS labeling works, what a compliant written HazCom program looks like, and how to prepare your team to respond when something goes wrong.
OSHA HazCom 2012 & GHS Overview
OSHA's Hazard Communication Standard (HazCom 2012) requires chemical manufacturers and importers to classify chemicals and communicate hazard information through labels and Safety Data Sheets (SDS). Employers who use hazardous chemicals must maintain a written HazCom program, keep SDS for every hazardous chemical in the workplace, ensure containers are properly labeled, and train employees on chemical hazards before initial assignment and when new hazards are introduced. The standard aligns with the United Nations' Globally Harmonized System of Classification and Labelling of Chemicals (GHS), which standardizes hazard categories, pictograms, signal words, and SDS format across countries — making it easier for workers to understand chemical hazards regardless of where a product was manufactured.
Key Action Items
- Develop and maintain a written HazCom program — it must be site-specific, available to all employees, and updated when new chemicals are introduced
- Compile and maintain a complete chemical inventory for every hazardous substance present in the workplace
- Obtain and keep an SDS for every hazardous chemical — SDSs must be readily accessible to employees during their shift
- Ensure all containers are labeled with the product identifier, signal word, hazard statements, pictograms, and supplier information
- Train employees on HazCom before they are exposed to hazardous chemicals — not after an incident
- Review and update your HazCom program whenever new chemicals are introduced or existing hazard information changes
GHS Labeling Requirements
Under GHS, every hazardous chemical container must display six required label elements: a product identifier, supplier information, signal word (Danger or Warning), hazard statements, precautionary statements, and pictograms. There are nine GHS pictograms covering health hazards, physical hazards, and environmental hazards — each a red-bordered diamond with a black symbol on a white background. Signal words indicate severity: 'Danger' is used for more severe hazards, 'Warning' for less severe. Workplace labels on secondary containers (those filled from a larger container) must include at minimum the product identifier and words, pictures, or symbols that provide general information about the hazards. Employers may use alternative workplace labeling systems (such as NFPA or HMIS) as long as employees are trained on the system used.
Key Action Items
- Verify that all incoming chemical containers have GHS-compliant labels before they are placed into service
- Never remove or deface a label on a hazardous chemical container — replace damaged labels immediately
- Label all secondary containers with at minimum the product identifier and hazard information
- Train employees to recognize all nine GHS pictograms and understand what each communicates about the chemical's hazard class
- Portable containers used and emptied within a single work shift by the person who filled them are exempt from labeling — all others must be labeled
- If using an alternative labeling system (NFPA, HMIS), document it in your written HazCom program and train all employees on its meaning
Safety Data Sheets (SDS)
Safety Data Sheets are the primary source of detailed hazard information for chemical substances and mixtures. Under GHS/HazCom 2012, every SDS must follow a standardized 16-section format covering identification, hazard identification, composition, first-aid measures, fire-fighting measures, accidental release measures, handling and storage, exposure controls and PPE, physical and chemical properties, stability and reactivity, toxicological information, ecological information, disposal considerations, transport information, regulatory information, and other information. Employers must ensure SDSs are accessible to employees in their work area during every shift — electronic access is permitted as long as there is no barrier to immediate access and a backup system exists for power outages or computer failures.
Key Action Items
- Maintain an SDS for every hazardous chemical in the workplace — no exceptions, including cleaning products and maintenance chemicals
- Ensure SDSs are immediately accessible to employees during their shift — locked cabinets or password-protected systems that create barriers are non-compliant
- If using electronic SDS access, maintain a written backup procedure for power outages or system failures
- Review SDSs when new chemicals are introduced — verify the SDS is current (within 3 years) and matches the product you received
- Train employees on how to read and use an SDS — focus on Sections 2 (hazards), 4 (first aid), 6 (spill response), 8 (PPE), and 14 (transport)
- Keep SDSs for discontinued chemicals for 30 years — OSHA requires records of employee exposure to hazardous substances to be retained long-term
Employee Training Requirements
HazCom training must be provided before employees are initially assigned to work with or in an area where hazardous chemicals are present, and whenever a new chemical hazard is introduced. Training must cover the requirements of the HazCom standard, the location and availability of the written HazCom program and SDSs, methods to detect the presence or release of hazardous chemicals, physical, health, simple asphyxiation, combustible dust, and pyrophoric gas hazards, and the measures employees can take to protect themselves. Training must also cover the details of the employer's HazCom program — including an explanation of the labeling system and how to read an SDS. Generic awareness training is not sufficient; training must be specific to the chemicals present in the employee's work area.
Key Action Items
- Train employees before initial assignment to any area where hazardous chemicals are present — not during orientation week, before day one in the area
- Conduct chemical-specific training — cover the actual chemicals in the employee's work area, not just generic hazard categories
- Cover all required topics: HazCom standard overview, written program location, SDS access, hazard detection, protective measures, and labeling system
- Retrain employees when new chemical hazards are introduced into their work area
- Document all HazCom training with employee name, date, chemicals covered, training method, and trainer signature
- Verify comprehension — use a short quiz or demonstration to confirm employees can read a label, locate an SDS, and identify the PPE required for their chemicals
Spill Response & Emergency Procedures
Every workplace that uses hazardous chemicals must have written emergency response procedures for accidental releases. The level of response capability required depends on the chemicals present and the quantities involved. OSHA's HAZWOPER standard (29 CFR 1910.120) applies to employees who respond to hazardous substance emergencies beyond incidental releases. An incidental release is one that does not pose a significant safety or health hazard, can be absorbed or neutralized by employees in the immediate release area, and does not require evacuation. Any release that exceeds this threshold requires trained HAZWOPER responders. At minimum, every workplace should have a written spill response procedure, appropriate spill containment materials, and employees trained to recognize when a spill exceeds their response capability and evacuation is required.
Key Action Items
- Develop written spill response procedures for every hazardous chemical — include containment, cleanup, disposal, and notification steps
- Stock appropriate spill containment materials (absorbents, neutralizers, containment booms) for the chemicals present in your facility
- Train employees to distinguish an incidental release (handle in-house) from an emergency release (evacuate and call for trained responders)
- Employees who respond to hazardous substance emergencies beyond incidental releases must be trained to HAZWOPER standards
- Post emergency contact numbers — including the facility emergency coordinator, local fire department HAZMAT team, and CHEMTREC (1-800-424-9300) — at every chemical storage area
- Conduct spill response drills at least annually — time the response, evaluate PPE use, and debrief on gaps in procedure or equipment
DOT Hazardous Materials Transport
Employers who ship or transport hazardous materials are subject to the U.S. Department of Transportation's Hazardous Materials Regulations (HMR, 49 CFR Parts 171–180). DOT requirements cover classification, packaging, marking, labeling, placarding, and documentation for hazardous materials in transport. Even businesses that only occasionally ship small quantities of hazardous materials — such as batteries, aerosols, or cleaning chemicals — may be subject to HMR requirements. Employees who prepare hazardous materials for transport, or who handle, mark, label, or placard packages, must receive DOT hazmat employee training within 90 days of hire and recurrent training every three years. Violations of DOT HMR can result in civil penalties of up to $84,425 per violation per day.
Key Action Items
- Determine whether any materials you ship are classified as DOT hazardous materials — consult the Hazardous Materials Table (49 CFR 172.101)
- Train all hazmat employees within 90 days of hire and every three years thereafter — training must cover general awareness, function-specific, safety, and security topics
- Use only DOT-specification packaging for hazardous materials — verify packaging is appropriate for the hazard class and quantity being shipped
- Complete a Shipper's Declaration (hazmat shipping paper) for every hazardous materials shipment — retain copies for two years
- Apply correct DOT labels and markings to packages and placards to vehicles as required by the hazard class and quantity
- Develop a written security plan if you ship select agents or large quantities of hazardous materials — required under 49 CFR 172 Subpart I
Chemical Hazards Are Manageable — With the Right Training
Is Your Team Ready to Handle a Chemical Emergency?
HazCom compliance and HAZMAT preparedness require more than a binder on a shelf. Contact us for a free needs analysis and let's build a hazardous materials training program that protects your workers and keeps your business compliant.