OSHA HazCom Violations: What the Data Reveals and How to Be Prepared

HazCom is a paperwork citation with a price tag that depends on what else the inspector finds

Over the past three years, 10,878 OSHA inspections cited the Hazard Communication standard. In every industry, the written program and employee training are the two most-cited paragraphs. The third is either safety data sheets or labels, depending on the industry, and the cost of an inspection varies even more.

inspections cited HazCom in three years

10,878

of them cited the written program, (e)(1) (opens in a new window)

64%

also cited something other than HazCom

86%

in HazCom penalties, 20% of the total

$19.7M

Which HazCom paragraphs does OSHA cite most?

These eight paragraphs of 29 CFR 1910.1200 cover every HazCom requirement cited on 100 or more inspections. One inspection can cite several paragraphs, so the shares add up to more than 100%.

Five things that stand out

1. The written program comes first. (e)(1) (opens in a new window) appears on 7,016 inspections, nearly two in three. In construction it is on 77% of HazCom inspections, and in repair shops and restaurants/hotels on 71%. If an employer has one HazCom citation, it is usually this one.
2. Construction is missing SDSs; manufacturing is missing labels. Construction accounts for 38% of inspections citing (g)(1) (opens in a new window) (no SDS on file) but only 8% of those citing (f)(6) (opens in a new window) (container labels). Manufacturing is the reverse: (f)(6) (opens in a new window) shows up on 25% of its HazCom inspections, against 9% for (g)(1) (opens in a new window). Chemicals arriving at a jobsite lose their paperwork, and chemicals decanted on a plant floor lose their labels.
3. The smallest column carries the biggest fines. Transport & Warehousing has the fewest HazCom inspections (362), yet it has the highest average fine in each of the three most-cited rows: $11.8k for the written program, $16.0k for training and $20.3k for SDS access.
4. Detailed citations mean bigger cases. In manufacturing, inspections citing the broad training requirement (h)(1) (opens in a new window) average $12.0k. Those citing the specific training content, (h)(3) (opens in a new window), average $26.5k, the highest cell on the chart. An inspector who checks what the training covered is usually running a longer, wider inspection.
5. Public employers pay the least. Public Administration has the lowest average fine in three rows: labels ($2.1k), SDS on file ($2.0k) and training content ($1.6k). This is consistent with state plans, which cover most public employers and often reduce or waive their penalties.

Which HazCom citations cost the most?

Average total fine per inspection, after settlements, for industry and paragraph combinations with at least 25 inspections.

More from the data

• Gaps come in clusters. Almost half of these inspections (49%) cited two or more HazCom paragraphs, and a quarter cited three or more. A missing program usually means missing training and missing SDSs as well.
• Most HazCom citations are rated serious. Of 20,611 HazCom line items, 58% were serious and 39% other-than-serious. Only 495 were repeats and 28 were willful.
• Manufacturing is the largest share. Factories account for 31% of HazCom inspections and have a large bubble in every row. Construction is next at 20%.
• Auto shops are a hotspot. Repair & Personal Services has 835 HazCom inspections, 82% of them in repair and maintenance (NAICS 811). Fines there are mostly modest ($4–7k), but the citations keep coming.
• About one in five cost nothing. 2,360 inspections (22%) closed with no fine at all after settlements.

How to avoid the most common HazCom citations

• Write the program down, and keep it specific to the site. It is the citation most likely to be issued. You don’t have to start from a blank page: OSHA’s Small Entity Compliance Guide (opens in a new tab) includes a sample written program in Appendix A, and some state-plan OSHA programs publish their own templates.
• In construction, make the SDS travel with the product: no chemical arrives on site without its SDS.
• In manufacturing, label every secondary container. Decanted chemicals are where (f)(6) (opens in a new window) citations come from.
• Keep training records that show what was covered, not just who attended. That is the gap behind (h)(3) (opens in a new window), the most expensive cell on the chart.

Full data: HazCom citations by paragraph and industry

Each cell shows the number of inspections citing that paragraph, then the average total fine per inspection.

Methodology

• Source: U.S. Department of Labor OSHA enforcement data, federal and state-plan inspections.
• Scope: inspections opened October 1, 2023 through August 4, 2026 (the latest HazCom inspection in the data) that cited 29 CFR 1910.1200, in every industry including construction: 10,878 inspections.
• Paragraphs are rolled up to the second level, so a citation of 1910.1200(f)(6)(ii) (opens in a new window) counts as (f)(6) (opens in a new window). An inspection is counted once per paragraph, however many line items cite it.
• Average fine is the mean of each inspection’s total current penalty, after settlements, across all of its violations, not just HazCom. Paragraph-level penalties are unreliable because grouped items carry the whole penalty on one line and $0 on the rest.
• Industry groups follow NAICS sectors. “All Other” covers agriculture, mining, utilities, administrative and waste services, education, recreation and the remaining sectors.