WORKER SAFETY: Hazard Communication
Hazard Communication in FDA Workplaces: A Role-Based Overview
FDA-regulated workplaces handle chemicals, biological materials, cleaning agents, and hazardous substances every day. Knowing what those substances are, how to read their labels, where to find their Safety Data Sheets, and what to do if something goes wrong is not optional. It is a core part of your job, and OSHA’s Hazard Communication Standard at 29 CFR 1910.1200 requires your employer to make sure you have that information.
Why This Matters to You
Many chemicals found in pharmaceutical and FDA-regulated workplaces look harmless. Some have no smell. Some cause damage only after months or years of repeated exposure. You cannot tell by looking at a container whether what is inside can burn your skin, damage your lungs, or affect your reproductive health. Labels, Safety Data Sheets (SDS), and training exist precisely because you should not have to guess. Understanding hazard communication means you know what you are working with, what protection you need, and what to do if something goes wrong.
Hazard Overview: What You Are Likely Working With
FDA-regulated facilities including pharmaceutical manufacturing, laboratory testing, compounding, and food processing environments share a common set of hazard categories. These are not ranked by severity but by how commonly workers encounter them without recognising the risk.
Cleaning and Disinfecting Agents
Very Common
Quaternary ammonium compounds, bleach solutions, alcohols, and peracetic acid are used extensively for sanitisation in pharmaceutical and food facilities. Many are corrosive or respiratory irritants at working concentrations.
Solvents and Reagents
Very Common in Labs
Methanol, isopropanol, acetonitrile, and ethyl acetate are common in analytical laboratories. Many are flammable and their vapours can accumulate to dangerous levels in poorly ventilated spaces.
Active Pharmaceutical Ingredients (APIs)
Highly Potent, Low Visible Risk
Some APIs are pharmacologically active at microgram levels. Skin contact, inhalation of dust, or mucous membrane exposure can cause unintended drug effects. Containment and PPE requirements depend on the potency category assigned to the material.
Compressed Gases and Cryogens
Physical and Chemical Hazards
Nitrogen, argon, and carbon dioxide are used for blanketing, purging, and cryogenic storage. Liquid nitrogen causes severe cryogenic burns on contact and can displace oxygen in confined spaces without any visible warning.
Signs of Danger You Should Never Ignore
A container with no label or a damaged label
Do not use it. Do not move it. Report it to your supervisor immediately. A missing or unreadable label means you have no information about what is inside, what hazards it poses, or what to do if there is a spill or exposure.
A strong or unusual smell you cannot identify
Leave the area. Tell your supervisor. Do not try to locate the source by smell. Odour thresholds for many solvents are above the level at which they cause harm, which means by the time you can smell it strongly, your exposure may already be significant.
Skin irritation, eye watering, or headache during or after work
These can be early signs of chemical exposure. Report symptoms to your supervisor and seek first aid. Do not wait to see if symptoms improve on their own. Document when the symptoms started and what you were doing at the time.
GHS pictograms you do not recognise on a container
The skull and crossbones, flame, corrosion symbol, and exclamation mark each carry specific meaning. If you see a pictogram and do not know what it means, look up the SDS for that chemical before handling it, and ask your supervisor.
Safe Work Practices by Role
In FDA-regulated facilities, hazard communication is not a single person’s job. Different roles carry different responsibilities under OSHA’s HazCom Standard. Knowing your specific obligations helps the whole programme function.
1
Frontline Workers and Lab Technicians
You are closest to the chemicals. Your safe work practices directly determine your own exposure level.
Read the label before opening any container
Know where the SDS binder or electronic SDS system is for your work area
Wear the PPE specified for the task before you start, not after something goes wrong
Never transfer a chemical to an unlabelled or incorrectly labelled secondary container
Report any missing, damaged, or illegible labels to your supervisor before handling the container
2
Supervisors and Team Leads
Your job is to make sure HazCom requirements are actually being followed during daily operations, not just on paper.
Verify that SDS are accessible and current for every chemical in your work area
Brief new workers and anyone assigned to a new task on the chemical hazards they will encounter
Conduct regular walkthroughs to check that labels are intact and containers are properly stored
Ensure that PPE appropriate to the hazards is available and in good condition before each shift
Report new chemicals introduced to the work area to the safety team for SDS procurement before use
3
Safety Officers and EHS Teams
You own the written HazCom programme and are responsible for keeping it compliant and functional across all work areas.
Maintain the written Hazard Communication Program per 29 CFR 1910.1200(e)
Keep the chemical inventory list current and ensure an SDS is on file for every listed chemical
Deliver initial and refresher HazCom training and document completion for all employees
Review and update the HazCom programme whenever new chemicals are introduced or hazards change
Investigate chemical exposure incidents and incorporate findings into training and programme updates
Do and Don’t: Chemical Handling in FDA Workplaces
DO
DO NOT
Read the SDS before working with any unfamiliar chemical
Do not assume a chemical is safe because it has no strong odour or does not immediately irritate your skin
Wear the PPE specified on the SDS or in your facility’s procedure for that chemical
Do not remove or deface labels on chemical containers for any reason
Label all secondary containers immediately when transferring chemicals
Do not eat, drink, or apply cosmetics in areas where chemicals are used or stored
Report unlabelled, damaged, or leaking containers to your supervisor before touching them
Do not mix chemicals unless the procedure specifically authorises it and you have been trained on the hazards of the combination
Store chemicals in their designated location, in compatible groupings, away from incompatible materials
Do not use a chemical to clean up a spill of a different chemical unless you know they are compatible
PPE Requirements for Common Hazardous Tasks
Handling Liquid Chemicals
Chemical-resistant gloves appropriate to the specific chemical (check SDS for glove material recommendation)
Safety glasses at minimum; chemical splash goggles where there is a splash risk
Lab coat or chemical-resistant apron
Closed-toe shoes; no sandals or fabric shoes in chemical handling areas
Working With Powders or Dusts
Nitrile gloves minimum; check SDS for specific recommendation
N95 or higher respirator if dust is generated and local exhaust ventilation is not controlling exposure
Safety glasses or goggles to protect eyes from airborne particles
Work in a ventilated area or contained enclosure where the material is potent or hazardous
Corrosive Chemicals (Acids, Bases)
Heavy-duty chemical-resistant gloves (neoprene or butyl rubber, not standard nitrile)
Chemical splash goggles, not just safety glasses
Face shield over goggles when pouring or transferring concentrated acids or bases
Chemical-resistant apron or full suit depending on quantity; know where the nearest eyewash and safety shower are before starting
Flammable Solvents
No ignition sources in the work area; confirm ventilation is adequate before opening large containers
Chemical-resistant gloves; many solvents permeate standard nitrile quickly (check SDS breakthrough time)
Safety glasses minimum; face shield if transferring large volumes
Ground containers to prevent static discharge when dispensing from large containers
Emergency Response
Chemical Spill
Alert others in the area. Do not attempt to clean up a spill involving a chemical you have not been trained to handle. Follow your facility’s spill response procedure. For small, contained spills of chemicals you are trained to handle: use appropriate PPE and spill kit materials. For large spills or spills of highly hazardous materials: evacuate the area, contain the spill if safe to do so from a distance, and contact emergency response.
Skin or Eye Contact
Move to the eyewash or safety shower immediately. Flush eyes with water for at least 15 minutes, holding eyelids open. For skin: remove contaminated clothing and flush with water for at least 15 minutes. Do not stop flushing early because you think it is enough. Seek medical attention after decontamination. Report the incident to your supervisor.
Inhalation
Move to fresh air immediately. If the person is not breathing or is unconscious, call 911. For mild symptoms such as headache, dizziness, or throat irritation: remove from the area, rest, and monitor. Do not re-enter the area where the exposure occurred without respiratory protection. Report to your supervisor and seek medical evaluation.
Before an emergency happens
Know where the nearest eyewash station and safety shower are in your work area. Confirm they are reachable within 10 seconds of any location where you handle corrosive materials. Know your facility’s emergency number and the location of the first aid kit. These are things to find out before you need them.
Supervisor Tips
What Good Supervisors Do That Others Don’t
Make SDS accessible, not just available
Having SDS in a binder in the office satisfies the technical requirement. Knowing whether workers can actually find the SDS for the chemical they are currently handling in under two minutes is what matters in practice. Walk through your area and check.
Brief new workers before they touch anything
New workers and temporary employees often cause or experience incidents in the first week. A brief task-specific chemical hazard discussion before they start a new process costs five minutes. It also fulfils a specific OSHA obligation to provide training before initial assignment.
Address label and SDS gaps the day they are found
Unlabelled containers and missing SDS tend to accumulate when they are not addressed immediately. A container set aside to “deal with later” is a container that may be handled by someone who does not know what is in it. Same-day resolution is a reasonable standard.
Document new chemical introductions before use
In FDA-regulated facilities, new chemical introductions may also trigger change control, procurement approval, and safety review requirements beyond HazCom. Establishing the habit of flagging new chemicals before they arrive on the bench prevents both safety gaps and compliance issues downstream.
Worker Checklist
Before Your Shift
Know which chemicals you will be working with today
Confirm your PPE is available and in good condition
Know the location of the SDS for your assigned chemicals
Know where the eyewash and safety shower are in your work area
During Your Shift
Read the label before opening any container you have not used before
Wear the correct PPE for each task before starting
Label any secondary containers immediately
Report unlabelled, damaged, or leaking containers right away
If Something Goes Wrong
Skin or eye contact: flush with water for at least 15 minutes
Inhalation: move to fresh air immediately
Spill: alert others, follow spill response procedure
Report every incident to your supervisor, even if you feel fine
Key Takeaways
The SDS is your primary source of hazard information
Every chemical in your workplace has a Safety Data Sheet with 16 sections covering its hazards, safe handling requirements, PPE specifications, first aid measures, and spill procedures. Your employer is required to make these accessible to you at all times during your shift. If you do not know where they are, ask today.
HazCom applies to your role, not just to the safety team
OSHA’s HazCom Standard creates obligations at every level of the facility. Workers are expected to follow safe work practices and use PPE. Supervisors are expected to ensure SDS access and brief workers on hazards. Safety officers are expected to maintain the written programme and training records. Knowing your specific role in this chain is part of what the programme requires.
Frequently Asked Questions
What is a Safety Data Sheet and where do I find one?
An SDS is a 16-section document describing a chemical’s hazards, safe handling requirements, PPE specifications, first aid procedures, and emergency response information. OSHA requires your employer to have one for every hazardous chemical and to keep them accessible during every work shift. Ask your supervisor where to find them in your work area before you need one.
What do I do if I find a container with no label?
Do not use it, move it, or open it. Isolate it if you can without touching it and report it to your supervisor immediately. An unlabelled container could contain anything, and without the label you have no information about its hazards. OSHA requires that all containers of hazardous chemicals in the workplace carry labels with the product identifier, hazard pictograms, signal word, hazard statements, precautionary statements, and the manufacturer’s information. Your supervisor is responsible for resolving the situation before work involving that container resumes.
Am I required to wear PPE if I only handle a chemical briefly?
Yes, if the task involves exposure to a hazardous chemical. The duration of exposure does not determine whether PPE is required. OSHA and most facility safety procedures require PPE based on the nature of the hazard and the task, not on how long the task takes. Many chemical exposures that cause the most serious long-term health effects involve repeated brief contacts rather than extended single exposures. If the SDS or your facility’s procedure specifies PPE for a task, it is required regardless of how quickly you expect to finish.
What should I do if I am asked to handle a chemical I have not been trained on?
Tell your supervisor before you start and ask for a briefing. OSHA requires employers to provide hazard communication training before initial assignment to any work involving hazardous chemicals, and again whenever a new hazard is introduced. Asking for that training before you touch the chemical is exercising a legal right under 29 CFR 1910.1200, not refusing work. In FDA-regulated environments, this matters doubly: some chemicals in pharmaceutical and laboratory settings are pharmacologically active or highly hazardous at very low exposure levels, and the SDS is the only document that will tell you what those hazards are. If your supervisor is unavailable, review the SDS yourself before proceeding and report the training gap to your EHS team the same day.
Government and Regulatory Sources
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Questions? Ask Before You Handle
Hazard communication works when people use it. If you are ever unsure about what a chemical is, what hazards it carries, what PPE you should be wearing, or what to do in an emergency, the right move is to ask your supervisor or check the SDS before you proceed. That is what the programme is there for. Find more worker safety resources at velsafe.com.
