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Does my propane company need a written Hazard Communication program?

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By Bill Stomp, Founder/Editor · Last updated November 4, 2026

Question: “Does my propane company need a written Hazard Communication program?”

Yes. OSHA's Hazard Communication rule, 29 CFR 1910.1200, calls for a written program at each workplace where your employees work with propane.

Do we need one for every location?

A written program must meet the requirements for each covered workplace. Paragraph (e)(3) allows an existing program if it meets paragraph (e), including workplace-specific requirements. This does not automatically require a separate document for every location. Under (e)(5), when employees travel between workplaces during a shift, the program may be kept at the primary workplace facility. It must be available on request as required by (e)(4).

Where do the safety data sheets go?

Paper or electronic copies are allowed. Under (g)(8), safety data sheets must be readily accessible to employees in their work areas during each shift. Electronic access must create no barriers to immediate employee access in each workplace. Under (g)(9), traveling employees' sheets may be kept at the primary workplace facility only if employees can immediately obtain the required information in an emergency.

What else should the program cover?

The written program must also list the hazardous chemicals on site and say how you handle container labels, safety data sheets and employee training. Read paragraphs (e) through (h) of the rule and match them to your yard and your trucks.

We help with safety manual writing, review and revision; see propane safety help.

Frequently asked questions

Is a binder required for safety data sheets?

No. Electronic access is permitted if it creates no barriers to immediate employee access in each workplace during each shift. For employees traveling between workplaces, sheets may be kept at the primary workplace facility if employees can immediately obtain the required information in an emergency.

Is one program enough for several locations?

An existing program may serve if it meets paragraph (e), including workplace-specific requirements. Under (e)(5), a program for employees traveling between workplaces during a shift may be kept at the primary workplace facility. The program must remain available on request under (e)(4).

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