Section 5.2 – Hazard Communication, Safety Data Sheets, and Chemical Labeling

The Hazard Communication Standard is intended to ensure that the hazards of workplace chemicals are classified and that information about those hazards and appropriate protective measures is communicated to employees. Chemical manufacturers and importers classify hazards and prepare labels and Safety Data Sheets. Employers then use that information to create a workplace program, label containers, maintain SDS access, and train exposed employees.

In a salon, the standard may apply to products such as hair color and developer, lightener, relaxers, permanent-wave solutions, smoothing products, nail monomers and polymers, adhesives, solvents, disinfectants, cleaning products, and aerosol sprays. Whether a particular product is hazardous depends on its classification and use, not simply on whether it is sold to consumers or used in the beauty industry.

Some consumer products may have limited exemptions when workplace use is essentially the same as ordinary consumer use. However, repeated professional use, larger quantities, longer exposure, or different application methods may remove the basis for that assumption. Employers should evaluate actual workplace use instead of automatically treating every retail product as exempt.

An employer with hazardous chemicals in the workplace must develop and maintain a written hazard communication program describing how the workplace will meet labeling, SDS, and training requirements. The program should be specific enough that a manager or employee can understand how chemical information is controlled in that salon.

• A current list or inventory of hazardous chemicals known to be present;
• Methods used to ensure shipped containers and workplace containers are properly labeled;
• Procedures for obtaining, maintaining, and providing access to Safety Data Sheets;
• Employee information and training procedures, including training for newly introduced hazards;
• Methods for informing employees about non-routine tasks and hazards from chemicals in unlabeled pipes, when relevant;
• Procedures for multi-employer workplaces when another employer’s workers may be exposed.

A written program should reflect actual salon operations. A generic policy copied from another business may fail if it lists products the salon does not use, omits current products, or gives employees an SDS location that is not accessible during the shift.

The chemical inventory is the bridge between products physically present in the workplace and the hazard information maintained for employees. The product identifier on the inventory should match the identifier on the label and SDS closely enough that employees can find the correct document without guessing.

Before a new product is introduced, the employer should obtain and review the SDS, evaluate the intended task, determine whether ventilation or PPE must change, verify storage compatibility, update the inventory, and train employees before they are exposed. Product demonstrations should not bypass this process.

A shipped-container label for a hazardous chemical generally includes six core elements: the product identifier; supplier identification; a signal word; hazard statements; precautionary statements; and one or more pictograms when required. Supplemental information may also appear. Employees should read the complete label rather than relying on the product name or color of the container.

Pictograms provide quick visual recognition, but they do not replace the text on the label or the SDS. The same pictogram may represent more than one hazard, and some hazards do not require a pictogram. Employees should be trained to interpret the image together with the signal word and hazard statements.

When a hazardous chemical is transferred from its original container into another workplace container, the employer must ensure the secondary container is identified and employees receive hazard information. A compliant workplace label may use the same information as the shipped label or another system that communicates the product identity and general hazard information together with the written program and training.

A narrow immediate-use exception may apply when an employee transfers a chemical into a portable container for that employee’s immediate use during the same work shift. The exception should not be stretched to cover bottles left overnight, shared among employees, stored for later appointments, or moved to another area. In those situations, the container should be labeled.

• Do not use food or beverage containers for chemicals.
• Do not abbreviate the product name so heavily that employees cannot match it to the SDS.
• Replace damaged, stained, or unreadable labels promptly.
• Do not cover hazard information with price stickers or salon branding.
• Label dilution bottles with the exact product identity and any workplace hazard information required by the program.

The Safety Data Sheet is the primary technical reference for a hazardous chemical. OSHA requires a standardized 16-section format. Sections 1 through 11 and Section 16 contain information required under the OSHA format; Sections 12 through 15 are included for consistency with the GHS but OSHA does not enforce their content because other agencies regulate those subjects.

SDS documents must be readily accessible to employees during each work shift. Electronic systems are acceptable when employees can access them immediately and a reliable backup is available if power, internet, passwords, or equipment fail. A manager’s locked office, a personal phone that employees are not allowed to use, or a website requiring unknown credentials does not provide practical access.

Employees do not need to memorize every SDS section. They need to know where to look. Before routine use, Sections 2, 7, and 8 are especially useful for hazards, handling, storage, controls, and PPE. During an exposure, Section 4 supports first-aid decisions. During a spill, Section 6 guides isolation and cleanup. During a fire, Section 5 provides critical response information. When two products may be incompatible, Section 10 is important.

Employees must receive effective information and training at the time of initial assignment and whenever a new chemical hazard is introduced into the work area. Training may cover hazard categories rather than every individual product, but it must be specific enough for employees to understand the chemicals and tasks they actually encounter.

• How to detect a release or exposure, including odors, visible dust, irritation, spills, or monitoring methods;
• The physical and health hazards present in the work area;
• Measures employees can take to protect themselves;
• The employer’s written program, label system, chemical inventory, and SDS location;
• Emergency procedures and reporting expectations;
• The meaning of updated label and SDS information under the 2024 HCS amendments.

Training should be understandable in the employee’s language and vocabulary. A signature on a roster documents attendance but does not prove understanding. Demonstration, questions, practice locating an SDS, and task-specific discussion are stronger methods.

Safe storage protects the product, the worker, and the building. Containers should remain closed, upright, and protected from damage. Flammable products should be kept away from heat, sparks, flames, and incompatible oxidizers. Products should not be stored in direct sunlight, near food, in public areas, or where leaks can reach drains or electrical equipment.

Chemical exposure may occur through inhalation, skin contact, eye contact, or accidental ingestion. The best control is selected through the hierarchy of controls: eliminate an unnecessary hazard, substitute a safer product, use engineering controls such as local exhaust ventilation, adopt safer work practices and training, and use PPE as the final layer.

Ventilation should control contaminants at or near the source when possible. General room ventilation may dilute odors but may not adequately capture vapors or dust at a nail table, mixing station, or smoothing service. Keeping containers closed, using covered waste cans, dispensing small quantities, and avoiding aggressive shaking of powders also reduce exposure.

OSHA has warned that some hair-smoothing products may contain or release formaldehyde during use, including when heated. Marketing terms such as “formaldehyde free,” “natural,” or “organic” do not replace hazard evaluation. If employees experience burning eyes, throat irritation, coughing, wheezing, headaches, or strong persistent exposure during a service, the salon should stop and investigate rather than normalize the symptoms.

The employer should review the SDS, label, supplier information, ventilation, work practices, and applicable formaldehyde requirements. Conflicting information should be documented and resolved with the manufacturer or qualified safety assistance before continued use.

Scenario 1: Unlabeled Developer Bottle

A colorist finds a clear squeeze bottle marked only “20.” The employee believes it contains 20-volume developer but cannot confirm who filled it.

Appropriate response: Remove it from service. The number alone does not reliably identify the product or hazards. Identify and label it through established procedures or dispose of it properly.

Scenario 2: Missing SDS for a New Adhesive

A supplier demonstrates a new lash adhesive and leaves samples for immediate use, but no SDS is available.

Appropriate response: Do not introduce the product until the salon obtains and reviews the SDS, evaluates ventilation and PPE, updates the inventory, and trains affected employees.

Scenario 3: Lightener Dust

Employees routinely pour powdered lightener from shoulder height, creating visible dust.

Appropriate response: Change the dispensing method, keep containers close to the bowl, use ventilation, review the SDS, and use required PPE. Visible dust is evidence that the work practice should be improved.

Scenario 4: Electronic SDS System Fails

During an eye splash, the salon’s SDS website is unavailable and no employee knows the product’s first-aid instructions.

Appropriate response: Begin immediate flushing consistent with emergency procedure, contact emergency resources, and use the backup SDS system. The salon must correct the access failure.

Scenario 5: “Formaldehyde-Free” Smoothing Product

Workers develop burning eyes and coughing during heat application even though the label says “formaldehyde free.”

Appropriate response: Stop and evaluate. Review the SDS and manufacturer information, improve controls, and obtain qualified guidance. Marketing language does not override symptoms or exposure evidence.

• Review the chemical inventory at least periodically and whenever products are added or removed.
• Train employees before exposure, not after the first incident.
• Use the product identifier to match labels, inventory entries, and SDS documents.
• Keep electronic SDS systems simple and maintain an accessible backup.
• Treat missing labels, missing SDS documents, and unexplained symptoms as reasons to stop and verify.
• Do not use food containers or vague abbreviations for salon chemicals.
• Document corrective action after spills, exposures, or communication failures.

OSHA’s Hazard Communication Standard requires a coordinated system for classifying and communicating chemical hazards. In the salon, the system includes a written program, a current chemical inventory, readable labels, accessible Safety Data Sheets, and effective employee training. Each part supports the others.

Labels provide immediate hazard warnings through product identifiers, signal words, hazard statements, precautionary statements, and pictograms. Safety Data Sheets provide detailed information in a standardized 16-section format. Employees should know how to use the SDS before routine work and during spills, exposures, fires, and other emergencies.

Safe storage, secondary-container labeling, product review, ventilation, exposure controls, and prompt reporting turn hazard information into daily protection. When information is missing or conditions are unsafe, the professional response is to stop, verify, and correct the problem before work continues.

Chemical safety begins with accurate information and becomes effective through action. A labeled container, an accessible SDS, a trained employee, and a controlled work process allow salon services to be performed with greater confidence and lower risk.

Hazard communication should be visible in ordinary salon decisions: reviewing a new product before purchase, labeling a dilution bottle, keeping an SDS backup, separating incompatible chemicals, and responding promptly to symptoms or spills. These practices protect employees, clients, emergency responders, and the professional reputation of the salon.