1
Identify the program administrator and scope
Name the individual β by title and name β responsible for maintaining the plan. Confirm which facilities, departments, and job classifications are covered. If multiple sites are involved, note whether this is a site-specific or enterprise-wide plan.
π‘ Use a job title rather than a person's name as the primary reference β plans outlive individuals, and a title-based reference never becomes outdated.
2
Compile the chemical inventory
Walk every storage area, work zone, and utility room and list every chemical product in use or stored. Record the product name, manufacturer, CAS number if available, and the work area where it is used.
π‘ Include chemicals that seem minor β cleaning sprays, lubricants, and compressed gases are all covered by HazCom and are frequently missed in inventories.
3
Collect and organize Safety Data Sheets
Obtain a current SDS (dated within the last 5 years, or the most recent available) for every chemical on the inventory. File them in the order they appear on the inventory list and verify the SDS format follows the 16-section GHS structure.
π‘ Request SDS directly from manufacturers or distributors β third-party aggregator databases sometimes host outdated versions that do not reflect current GHS revisions.
4
Document labeling procedures
Specify the label standard for original containers (must not be removed or defaced) and the minimum required information for secondary containers. Identify who is authorized to create and apply secondary labels.
π‘ Pre-print a stock of secondary container labels with the company name, chemical identity field, and GHS pictogram blocks β it takes 30 seconds to complete one instead of improvising with a marker.
5
Define the training curriculum and delivery schedule
List the specific topics covered in HazCom training, the format (classroom, video, on-the-job), and the schedule for initial and refresher training. Attach the sign-in or completion record form.
π‘ Document training outcomes, not just attendance. A record showing employees demonstrated SDS comprehension holds up in an OSHA investigation far better than a sign-in sheet alone.
6
Address non-routine tasks and contractor procedures
List the non-routine tasks at your facility that involve chemical exposure and write a brief procedure for each. Then draft the contractor notification language and the form contractors must complete before bringing chemicals on site.
π‘ A one-page chemical hazard briefing form for contractors β listing the chemicals in their work area and the PPE required β takes 20 minutes to create and satisfies the notification requirement on every future job.
7
Set the review schedule and version-control the document
Add a header or footer with the document version number, effective date, and the name of the approving manager. Add a revision log table at the end to track future changes.
π‘ Schedule the annual review on a fixed calendar date β January 1 or the start of the fiscal year β so it does not get displaced by operational priorities.
8
Post, distribute, and communicate the plan
Post a notice in each work area directing employees to the location of the written plan and the SDS binder. Provide a copy to all supervisors and include plan location in new-employee orientation materials.
π‘ A laminated one-page summary posted at the chemical storage area β listing the SDS binder location, the spill response steps, and the emergency contact β is the single most-referenced output of the full plan.