Closing HazCom gaps through accountability

Most Hazard Communication audits are good at finding problems.

The findings are often familiar: missing Safety Data Sheets, outdated chemical inventories, employees who haven't completed required training, and secondary containers with incomplete labels.

The difficult part isn't identifying the gap. It's making sure the gap actually gets closed.

Why follow-through is the real challenge

Consider a common situation:

During an internal HazCom audit, a supervisor discovers that three chemicals in a maintenance shop don't have current SDSs available to employees.

The issue is documented. An email is sent to the purchasing department requesting updated SDSs from the supplier.

Then everyone gets busy.

A few weeks later, nobody is quite sure whether the SDSs were received. The original email is buried in someone's inbox. The auditor assumes the issue was fixed. The supervisor assumes someone else handled it.

Six months later, the same finding appears during the next audit.

This isn't unusual.

Most compliance failures don't happen because organizations ignore problems. They happen because corrective actions lose visibility after the audit is over.

What are corrective actions in HazCom?

Corrective actions are the specific steps taken to resolve identified gaps in a Hazard Communication program.

Examples include:

• Obtaining missing or updated SDSs

• Correcting chemical labels

• Updating the written HazCom program

• Removing obsolete chemicals from inventory

• Providing overdue employee training

• Verifying that new procedures are being followed

While OSHA does not prescribe a specific corrective action system, employers are expected to address identified deficiencies and maintain compliance with the Hazard Communication Standard.

Finding a gap is only the first step.

The real value comes from documenting what will be done, who will do it, and when it will be completed.

A HazCom gap isn't truly closed until the corrective action is completed, verified, and documented.

Turning findings into accountability

Every audit finding should lead to a clear next step:

• What needs to be fixed?

• Who owns the action?

• When is it due?

• How will completion be verified?

Organizations that consistently improve their HazCom programs create visibility around corrective actions rather than relying on memory, spreadsheets, and email chains.

Just as important, they maintain evidence that the issue was actually resolved. When a missing SDS is obtained, a label is corrected, or training is completed, there should be a record showing what was done, who completed it, when it was verified, who verified it, and who closed the issue.

This documentation creates a clear audit trail that managers can review at any time. Instead of wondering whether a finding was addressed months ago, they can quickly see the status of corrective actions, review supporting evidence, and confirm that gaps have been closed before the next audit or OSHA inspection.

Tools such as GapCross support this process by linking corrective actions directly to audit findings, assigning responsibility, tracking progress, collecting evidence of completion, and maintaining a permanent record of what was identified and how it was resolved. GapCross supports the efficient creation and assignment of tasks, collaboration between auditors and auditees, evidence collection, and tracking corrective actions throughout the assessment process.

Because at the end of the day, a gap that gets identified but never resolved—or can't be shown to have been resolved—is still a risk.

Coming next

We've covered inventories, SDSs, labels, training, audits, and corrective actions.

In the final post of this series, we'll bring everything together and discuss what it really means to be prepared for an OSHA inspection.