If your shop uses any chemicals that can hurt people, and that includes cleaners, solvents, paints, oils, welding gases, then you’re in OSHA territory. That’s basically every factory in North America, including the smallest ones.
If you manufacture, assemble, coat, clean, treat, or maintain anything using chemicals, you need HazCom. Machine shops, food processing plants (yes, even with sanitizers), wood shops with finishes, plastics, metal fabrication—doesn’t matter. If there’s a Safety Data Sheet (SDS) in your building, you need to track HazCom training.
Not just the guys on the floor. Anyone who could be exposed: operators, maintenance, janitorial staff, supervisors, even temps. If they could potentially come into contact with a chemical, they need training. Office staff usually don’t, unless they ever go into your production area or handle chemicals.
Day 1 for every worker who might come in contact. The rule is simple: train employees before they’re exposed to hazardous chemicals. Don’t wait until after an incident, or “when things slow down.” Also retrain anytime you introduce a new chemical or new hazard into the workplace., or when employees are assigned to new tasks with different hazardous chemicals. In practice, many factories make sure refresher training happens every year to cover their bases.
NOTE: With new 1/15/26 OHSA rules in force, employers must update employee training by November 20, 2026, for substances and by May 19, 2028 for mixtures.
As one safety professional put it, “If you ask workers about the chemicals they are using and get blank stares, that is a problem even if you have proof of training."2
Don’t over-complicate it. You don’t need a consultant just for this, and you don’t need to make your own elaborate training course. Use a solid online course that covers the points listed above (plenty are cheap), then make it real in the context of your actual shop. Walk employees through your factory’s chemicals and SDS sheets. Even if you use an online course, track everything about the training event: who took it, when, proof of completion, and the link to the course. That tracking matters for OSHA since they’ll want to see proof.
Tip: Use MakerComply’s Free Employee Training Tracker to keep clean, consistent records without the usual admin headache.
Disclaimer: This cheat sheet is meant to be an overview and does not take the place of full regulatory compliance guidance. For example, chemical manufacturers are subject to different rules. Consult OSHA for more information, especially 29 CFR 1910.1200(h).3
Sources:
http://osha.gov/sites/default/files/publications/OSHA2254.pdf
https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1200
If your shop uses any chemicals that can hurt people, and that includes cleaners, solvents, paints, oils, welding gases, then you’re in OSHA territory. That’s basically every factory in North America, including the smallest ones.
If you manufacture, assemble, coat, clean, treat, or maintain anything using chemicals, you need HazCom. Machine shops, food processing plants (yes, even with sanitizers), wood shops with finishes, plastics, metal fabrication—doesn’t matter. If there’s a Safety Data Sheet (SDS) in your building, you need to track HazCom training.
Not just the guys on the floor. Anyone who could be exposed: operators, maintenance, janitorial staff, supervisors, even temps. If they could potentially come into contact with a chemical, they need training. Office staff usually don’t, unless they ever go into your production area or handle chemicals.
Day 1 for every worker who might come in contact. The rule is simple: train employees before they’re exposed to hazardous chemicals. Don’t wait until after an incident, or “when things slow down.” Also retrain anytime you introduce a new chemical or new hazard into the workplace., or when employees are assigned to new tasks with different hazardous chemicals. In practice, many factories make sure refresher training happens every year to cover their bases.
NOTE: With new 1/15/26 OHSA rules in force, employers must update employee training by November 20, 2026, for substances and by May 19, 2028 for mixtures.
As one safety professional put it, “If you ask workers about the chemicals they are using and get blank stares, that is a problem even if you have proof of training.”
Don’t over-complicate it. You don’t need a consultant just for this, and you don’t need to make your own elaborate training course. Use a solid online course that covers the points listed above (plenty are cheap), then make it real in the context of your actual shop. Walk employees through your factory’s chemicals and SDS sheets. Even if you use an online course, track everything about the training event: who took it, when, proof of completion, and the link to the course. That tracking matters for OSHA since they’ll want to see proof.
Tip: Use MakerComply’s Free Employee Training Tracker to keep clean, consistent records without the usual admin headache.
Disclaimer: This cheat sheet is meant to be an overview and does not take the place of full regulatory compliance guidance. For example, chemical manufacturers are subject to different rules. Consult OSHA for more information, especially 29 CFR 1910.1200(h).
Sources:
http://osha.gov/sites/default/files/publications/OSHA2254.pdf
https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1200
