Pretty much every employer has chemicals in the workplace. Sometimes this requires training, sometimes it does not. For example, an office employee using a window cleaner like Windex every once in a while on the window of their office does not. However a janitorial person using the same Windex, and more importantly, who uses it every day does require a hazardous communication plan. Of course the more dangerous the chemical(s), the more likely an employer needs a formal program.
Lack of a Hazardous Communication plan is the second most cited violation on employers by Oregon OSHA. As of November 23, 2025 there were 324 violations with $228,462 in penalties.
A fully implemented hazard communication plan has these components:
- Written hazard communication policy.
- Safety Data Sheet (SDS) book located in a centralized location (or a digital system that EVERYONE can access).
- A written inventory of all chemicals in the building. This inventory must be the first page in the SDS book and be dated and updated annually.
- A process to catch all new chemicals coming into the organization so the safety data sheets are kept updated.
- A safety data sheet for every chemical on the inventory list. This information needs to be organized in a logical way (cleaners, greases and oils, fuels, etc.) with tabs.
- Required Employee training:
- All new hires must be informed of the hazard communication plan and location of the safety data sheets.
- Employees must know how to read the sheets (sections #4, #8 and #11 should be highlighted) and understand all nine GHS (Global Harmonized System) pictograms.
- Employees must be told of chemicals that they will be working with or in their work area before they are exposed.
- Annual training of the hazard communication plan.
Do you need help getting a hazardous communication plan in place? If you have workers’ compensation through Cardinal, you have access to SAIF’s safety specialist. This is a no cost service where you can get assistance, from creating a plan from scratch, to getting help with your current hazardous communication plan. Just reach out to Cardinal’s Risk Team at riskmanagement@cardinalservices.com.