How does an OSHA HazCom inspection work?
An OSHA Compliance Safety and Health Officer (CSHO) typically arrives unannounced, presents credentials, and holds an opening conference. They explain the scope (programmed, complaint-driven, or follow-up), then begin a four-part document and facility review. Expect the visit to last between 90 minutes and a full day.
The four-part inspection checklist
Part 1 — Your written hazard communication program
The inspector will ask to see your written program first. It must be site-specific, name the person responsible, describe how you maintain SDSs and labels, list every hazardous chemical on site, and explain your training program.
- Names a responsible person by title and current name
- Lists every hazardous chemical you currently store or use
- Describes your SDS retrieval system and where it lives
- Explains your secondary-container labeling process
- Documents your training schedule and topics covered
- Has been reviewed within the last 12 months
Part 2 — Your Safety Data Sheet library
An inspector will typically ask an employee to retrieve an SDS for a specific product. 29 CFR 1910.1200(g)(8) requires that SDSs be 'readily accessible' during each work shift to employees when they are in their work area(s). In practice, that means an employee can locate the sheet quickly without needing a manager, password, or special training — whether the library is paper or electronic.
- An SDS exists for every hazardous chemical on the inventory list
- Each SDS uses the modern 16-section GHS format (not the legacy MSDS format)
- Frontline employees can locate any SDS without manager assistance
- Digital SDS systems work even when Wi-Fi is down (printed backup or offline cache)
- SDSs match the products actually on shelves
Part 3 — The facility walk-through
This is where most small businesses lose points. The inspector walks every chemical storage area, every workstation, and every supply closet looking for containers without proper labels. Anything decanted from its original packaging needs a workplace label.
- Every secondary container has a workplace label naming the chemical and its hazards
- Original-manufacturer labels are not defaced or peeling
- Spray bottles in supply closets are labeled even if rarely used
- Container labels match the SDS in the library
- Chemicals are stored away from incompatibles (acid + bleach, oxidizers + fuels, etc.)
Part 4 — Training records
The inspector will ask to see signed acknowledgements showing each employee was trained on HazCom, the GHS label format, the SDS structure, and the specific hazards of chemicals in their work area. Training must be documented before initial assignment to a chemical task and refreshed when a new hazard is introduced.
- Signed training acknowledgement for every current employee
- Records cover initial assignment date for each employee
- Records show training in a language and at a literacy level the employee understands
- Topics include the four pillars: written program, SDSs, labels, and hazards in their work area
- Keep training records for at least the term of an employee's employment; if your facility also maintains exposure or medical records under 29 CFR 1910.1020, those are kept for the duration of employment plus 30 years
When we do mock inspections, the issue is rarely the binder. It's the spray bottle of degreaser under the sink. Two minutes into a walkthrough, we find the unlabeled container that would cost a real employer thousands of dollars.
What to do in the 30 minutes before an inspector arrives
- Print or pull up your written HazCom program — make sure the named contact is still employed.
- Confirm your SDS library is accessible from the work area, not just the manager's office.
- Walk the facility once and label any spray bottle, jug, or transfer container.
- Place the most recent training roster on top of the records folder.
- Designate a single point of contact to escort the inspector — do not let them roam alone.