Updating the Hazard Communication Program Toolbox Talk

A Hazard Communication (HazCom) Program is a living document that should be reviewed and updated whenever workplace conditions, hazardous chemicals, or work processes change. New chemicals, revised Safety Data Sheets (SDSs), updated labeling requirements, changes in regulations, and lessons learned from incidents all require the program to be evaluated. Keeping the Hazard Communication Program current helps ensure workers have accurate information to safely handle hazardous chemicals.

This toolbox talk reviews when the Hazard Communication Program should be updated and the responsibilities of workers and supervisors in maintaining an effective chemical safety program.

Why This Matters

• Workplace hazards change as new chemicals and processes are introduced.
• Outdated hazard information can increase the risk of chemical exposures and incidents.
• Current Safety Data Sheets (SDSs) and labels provide the latest hazard and emergency information.
• Program updates help ensure workers receive accurate training and hazard information.
• Regular reviews support regulatory compliance and continuous improvement.

Common Hazards

• Using outdated Hazard Communication procedures.
• Introducing new chemicals without updating the chemical inventory.
• Missing or outdated Safety Data Sheets (SDSs).
• Employees not being informed of new chemical hazards.
• Changes in work processes that increase chemical exposure risks.
• Incomplete or outdated container labeling procedures.
• Failure to revise emergency response procedures after incidents.
• Inadequate documentation of program revisions and employee training.

Safety Checklist

When Reviewing the Program

• Review the chemical inventory regularly and update it whenever chemicals are added or removed.
• Verify current Safety Data Sheets (SDSs) are available for every hazardous chemical on site.
• Confirm all chemical containers are properly labeled according to company procedures.
• Evaluate whether work processes or job tasks have introduced new chemical hazards.
• Review incident reports and inspection findings for opportunities to improve the program.
• Update written procedures as needed to reflect current workplace conditions and applicable regulations.

After Program Updates

• Communicate changes to all affected employees before work continues.
• Provide additional Hazard Communication training whenever new hazards or procedures are introduced.
• Replace outdated SDSs, labels, and written procedures with current versions.
• Verify emergency response procedures remain appropriate for the chemicals in use.
• Maintain documentation of program revisions and employee training.
• Encourage workers to report hazards or suggest improvements to the Hazard Communication Program.

Crew Talking Points

• Have any new hazardous chemicals been introduced since the last program review?
• Are current Safety Data Sheets (SDSs) available for every hazardous chemical on site?
• What changes require additional Hazard Communication training?
• How can workers report concerns or recommend improvements to the program?
• Who is responsible for maintaining the written Hazard Communication Program?
• Speak up immediately if you notice outdated hazard information, missing SDSs, or procedures that no longer match current work practices.

Stop Work If

• New hazardous chemicals are introduced without updating the Hazard Communication Program.
• Required Safety Data Sheets (SDSs) are missing or outdated.
• Chemical labels are missing, damaged, or inaccurate.
• Workers have not been informed of new chemical hazards or revised procedures.
• Emergency response procedures no longer match the hazards present.
• You are unsure whether current hazard communication information is accurate.

Final Reminder

A Hazard Communication Program must evolve as the workplace changes. Keep chemical inventories current, maintain up-to-date Safety Data Sheets and labels, provide training whenever hazards change, and encourage workers to report concerns. A regularly updated HazCom Program helps ensure everyone has the information needed to work safely with hazardous chemicals.