Audit Support: Hazard Communication Standard (HazCom) Audit

What Is a Hazard Communication (HazCom) Audit?

A Hazard Communication (HazCom) Audit is a structured evaluation of a workplace’s compliance with OSHA’s 29 CFR 1910.1200 requirements. These audits ensure employees are informed about hazardous chemicals and trained in protective measures. To remain compliant, employers must:

• • Maintain a written HazCom program
  • Keep chemical inventories current
  • Provide accessible Safety Data Sheets (SDSs)
  • Ensure accurate labeling of containers
  • Deliver effective employee training

Head over to SEC’s HazCom program development and training services to see how we can strengthen your program beyond auditing.

Types of HazCom Audits

HazCom audits may vary by scope and objective. Common categories include:

1. 1. Compliance Audits – Verify adherence to OSHA’s 29 CFR 1910.1200 requirements.
   2. Program Effectiveness Audits – Evaluate whether training, labeling, and SDS management are effective in practice.
   3. Management System Audits – Assess how HazCom integrates into broader EHS systems and leadership oversight.
   4. Internal Self-Audits – Conducted by facility staff to identify issues before OSHA inspections.
   5. Independent Third-Party Audits – Conducted by external experts, like SEC, to provide an unbiased evaluation and compliance assurance.

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HazCom Audit Process

A HazCom audit typically follows:

1. 1. Plan the Audit – Define the scope, frequency, and regulatory focus areas.
   2. Conduct the Audit – Perform walkthroughs, review documentation, and interview employees.
      1. OSHA inspection preparation often mirrors this step, including opening and closing conferences and site walkthroughs.
   3. Prepare the Report – Summarize findings, identify non-compliance issues, and provide recommendations.
   4. Implement Corrective Actions – Resolve identified issues within required timelines.
   5. Communicate Results – Share outcomes and corrective actions.

General Checklist for HazCom Audit

A thorough HazCom audit checklist includes:

1. 1. Written Program
      1. §1910.1200(e)(1): Program is written, identifies responsible personnel, maintains SDSs, coordinates training, lists workplace chemicals, and describes methods for informing employees of non-routine task hazards.
      2. §1910.1200(e)(2): Program explains how contractors are informed about hazardous chemicals and how SDSs are shared.
      3. §1910.1200(f): Explains labeling requirements.
      4. Best practice: Review SDSs before major changes and consider safer alternatives.
   2. Labels
      1. §1910.1200(f): All containers labeled with identity and hazard warnings, secondary containers (chemicals transferred to other containers) are properly labeled, alternative labeling systems (e.g., placards, batch tickets) may be used.
      2. §1910.1200(j): Manufacturer labels updated to include GHS pictograms.
      3. Best practice: Food containers are not reused for chemicals and “date opened” markings are applied.
   3. Safety Data Sheets
      1. §1910.1200(g): SDS available for every hazardous chemical, readily accessible to employees, and kept up to date.
      2. Best practice: Maintain an SDSs file with a table of contents; update promptly when revised SDSs are received.
   4. Training
      1. Employees trained when first assigned to work with hazardous chemicals.
      2. Refresher training is required when a new chemical hazard is introduced.
      3. Training focuses on hazard recognition, not just product names.

Staying Ahead of HazCom Auditing

Regular HazCom audits are essential for maintaining both workplace safety and regulatory compliance. Our SEC’s experts provide comprehensive audit support, and whether you need auditing, employee training, or full program development, we are here to help ensure your HazCom program remains effective, up to date, and inspection-ready!