Small employers rack up the most HazCom violations

It’s easy to assume that large employers with hundreds of chemicals are cited most often under OSHA’s Hazard Communication (HazCom) standard at 1910.1200. However, it’s just the opposite. Small employers – those with fewer than 20 employees – topped the list in fiscal year 2025. Following are the top five most frequently cited small employers:

#1 - Specialty trade contractors in construction (NAICS 238): 

• Foundation, structure, and building exterior contractors;
• Building equipment contractors;
• Building finishing contractors; and
• Other specialty trade contractors. 

#2 - Fabricated metal product manufacturing (NAICS 332):

• Forging and stamping;
• Cutlery and handtool manufacturing;
• Architectural and structural metals manufacturing;
• Boiler, tank, and shipping container manufacturing;
• Hardware manufacturing;
• Spring and wire products;
• Machine shops;
• Turned product;
• Screw, nut, and bolt manufacturing;
• Coating, engraving, heat treating, and allied activities; and
• Other fabricated metal product manufacturing.

#3 - Repair and maintenance (NAICS 811):

• Automotive repair and maintenance;
• Electronic and precision equipment repair and maintenance;
• Commercial and industrial machinery and equipment (except automotive and electronic) repair and maintenance; and
• Personal and household goods repair and maintenance.

#4 - Nonmetallic mineral product manufacturing (NAICS 327):

• Clay product and refractory manufacturing;
• Glass and glass products;
• Cement and concrete products;
• Lime and gypsum products; and
• Other nonmetallic mineral product manufacturing.

#5 – Merchant wholesalers, durable goods (NAICS 423):

• Motor vehicle and motor vehicle parts and supplies;
• Furniture and home furnishing;
• Lumber and other construction materials;
• Professional and commercial equipment and supplies;
• Metal and mineral (except petroleum);
• Household appliances and electrical and electronic goods;
• Hardware, and plumbing and heating equipment and supplies;
• Machinery, equipment, and supplies; and
• Miscellaneous durable goods.

When does HazCom apply and what’s required?

Any workplace where hazardous chemicals are present and employees can be exposed under normal conditions of use or in a foreseeable emergency is generally covered by the HazCom standard. (There are some exemptions from the standard at 1910.1200(b)(6).) Covered employers must:

• Develop and implement a written HazCom program. This includes creating and maintaining a list of all covered hazardous chemicals in the workplace, including those that are stored or not in use.
• Ensure there’s a Safety Data Sheet (SDS) for each hazardous chemical and that SDSs are accessible to employees.
• Ensure containers of hazardous chemicals are properly labeled.
• Communicate hazard information to employees through labels, SDSs, and training. Training must address:
  • The requirements of the HazCom standard;
  • The physical and health hazards of the chemicals in the work area and how employees can protect themselves;
  • How employees can detect the presence or release of a hazardous chemical in the work area; and
  • The details of the employer’s written HazCom program, labels, and SDSs, and how workers can obtain and use this information.

Prior to the initial job assignment, each employee who has exposure risks to hazardous chemicals must be provided information and training. Additional training must be done whenever a new physical or health hazard is introduced into their work area.

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