CAL/OSHA’s Must-Have Document: Why Your Written HAZCOM Plan is Non-Negotiable

North Coast wineries are centers of precision, blending art and science to craft world-class vintages. But behind the beautiful barrel rooms and crush pads lies an industrial environment where hazardous materials—from caustic cleaners and concentrated acids to fermentation aids—are used daily.
For operations involving these chemicals, Cal/OSHA’s regulations are crystal clear: A Written Hazardous Communication Plan (HAZCOM Plan) isn’t optional; it’s the law.
At Epsilon Consulting, we find that many wineries have the components—the Safety Data Sheets (SDSs) and basic training—but lack the essential, unifying blueprint that Cal/OSHA demands. Here’s why this written plan is vital for your compliance and worker safety.
The Legal Foundation: 8 CCR §5194
The requirement for a written HazCom Plan is explicitly laid out in Title 8, California Code of Regulations (8 CCR) §5194. This standard mandates that every employer with hazardous chemicals in the workplace must develop, implement, and maintain a comprehensive written program.

For a Cal/OSHA inspector, the HAZCOM Plan is the first document they ask for. It serves as your organization’s proof that you have a structured, effective system in place, rather than relying on ad-hoc or undocumented procedures.
The Absence of a Written Plan is an Automatic, High-Severity Violation.
More Than Just a Binder: The HazCom Blueprint
Your written HAZCOM Plan must describe, in detail, how your winery addresses the “Right to Know” for your employees. It must cover three key areas that tie all your chemical safety efforts together:
1. Chemical Inventory and Labeling
The plan must detail who is responsible for maintaining the chemical inventory and how you ensure all primary and secondary containers are properly labeled. This includes temporary tanks or transfer lines used during sanitation cycles. It must describe your system for verifying that every chemical on your property has a current, matching SDS.
2. SDS Accessibility
The plan must clearly state the location and method for providing employees immediate access to the SDSs for every hazardous chemical they may encounter during their shift. This is critical for all shifts. Whether it’s an electronic system, a dedicated computer, or a hard-copy binder, the plan must define the procedure.
3. Formal Employee Training
This is where the written plan proves its worth. It must describe the format, content, and frequency of HAZCOM training. This includes:
• Training for new hires and seasonal staff before they handle chemicals.
• Annual refresher training for all personnel.
• Training in newly introduced chemicals or revised procedures.
• Crucially, the training must cover how to interpret SDSs and container labels, not just where to find them.
Why a Generic Template Fails in the North Coast AVA
Wineries often rely on basic, downloaded templates for their safety programs. This can be a major compliance trap because the HAZCOM Plan must be site-specific and effective.
• Unique Chemical Mixtures: Your winery uses specific cellar chemicals, different cleaning protocols for stainless steel vs. oak, and unique processes (like filtering or Pressing) that generic templates don’t account for.
• Seasonal Staffing: The plan must explicitly address how temporary or harvest staff, who may speak different primary languages, receive effective and documented training.
• Non-Routine Tasks: When Cal/OSHA auditors check the plan, they look for procedures covering non-routine tasks, such as confined space entry (like cleaning a fermentation tank) or mixing concentrated chemicals for solution preparation. These specific tasks must be addressed in the written HAZCOM program.
Protect Your Employees, Protect Your Operation
The risk of non-compliance goes beyond fines. An inadequate HAZCOM plan directly contributes to worker injury and illness. By establishing a formalized, written plan, you are not only satisfying regulatory mandate but also:
• Reducing the likelihood of chemical accidents.
• Ensuring rapid, correct emergency response.
• Demonstrating management’s commitment to safety.
Don’t leave the core of your chemical safety program unwritten. Epsilon Consulting specializes in creating customized HAZCOM plans that seamlessly integrate with your existing winery operations, ensuring you meet the stringent requirements of Cal/OSHA 8 CCR §5194.
Michael Long, Manager Epsilon Water LLC – Epsilon Consulting
• Phone: 707-333-9167
• Email: michael@epsilonwater.com
• Website: epsilonwater.com