Any chemical product that poses a physical or health hazard requires a Safety Data Sheet (SDS). Under OSHA’s Hazard Communication Standard, the manufacturer, distributor, or importer of a hazardous chemical must provide an SDS to downstream users. This applies to pure substances and mixtures alike, covering everything from industrial solvents and compressed gases to cleaning sprays and adhesives used in a workplace.
What Makes a Product “Hazardous”
OSHA defines a hazardous chemical as any chemical that can cause a physical hazard or a health hazard. The chemical manufacturer is responsible for making that determination through hazard classification. If a product meets the criteria for even one hazard class, it needs an SDS.
Health hazards include acute toxicity (poisons), skin corrosion or irritation, serious eye damage, respiratory or skin sensitization (allergic reactions), cancer-causing potential, reproductive toxicity, and organ damage from single or repeated exposure. Physical hazards cover flammable liquids, flammable solids, explosives, oxidizers, compressed gases, self-reactive chemicals, pyrophoric materials (those that ignite on contact with air), and combustible dusts, among others.
These categories are broad by design. A product doesn’t need to be dramatically dangerous to qualify. A flammable liquid with a flash point below 200°F, a dust that can form an explosive cloud, or a substance that causes skin irritation all trigger the SDS requirement.
Common Workplace Products That Need an SDS
In practice, the range of products requiring an SDS is enormous. Some of the most common categories include:
- Cleaning chemicals: degreasers, disinfectants, floor strippers, oven cleaners, and bleach-based products
- Paints, coatings, and solvents: spray paints, lacquers, thinners, acetone, and mineral spirits
- Adhesives and sealants: epoxies, cyanoacrylates (super glue), silicone sealants, and construction adhesives
- Compressed and liquefied gases: oxygen, acetylene, propane, nitrogen, and carbon dioxide
- Fuels and petroleum products: gasoline, diesel, kerosene, and hydraulic fluids
- Welding and metalworking materials: welding rods, cutting fluids, and flux
- Pesticides and herbicides: any product used for pest or weed control
- Laboratory chemicals: acids, bases, reagents, and synthesized compounds distributed to other workplaces
If a product has a hazard pictogram, signal word, or hazard statement on its label, it almost certainly has an SDS behind it.
How Mixtures Are Classified
Many workplace products are mixtures rather than pure chemicals. A mixture needs an SDS when it contains hazardous ingredients above certain concentration thresholds. These thresholds vary depending on the type of hazard.
For the most serious health concerns, the cutoffs are low. A mixture containing a carcinogen, reproductive toxicant, respiratory sensitizer, or germ cell mutagen at just 0.1% or higher must be classified for that hazard and carry an SDS. For organ toxicity from single or repeated exposure, the threshold is 1.0%. For less severe effects like respiratory irritation, the cutoff rises to 20%. These low thresholds mean that even products with small amounts of hazardous ingredients can trigger SDS requirements.
Products That Are Exempt
Not everything in a workplace needs an SDS. OSHA carves out several important exemptions.
Articles
A manufactured item counts as an “article” and is exempt from SDS requirements if it meets all three of these conditions: it’s formed to a specific shape or design during manufacturing, its function depends on that shape or design, and it does not release more than trace amounts of a hazardous chemical under normal use. Think of a metal pipe, a plastic fitting, or a wooden board. These are solid objects whose hazard potential is locked into their physical form.
This exemption has limits that catch people off guard. Lithium-ion batteries, for example, are not considered articles under OSHA’s rules. Even though they’re sealed manufactured items, they have the potential to leak, spill, or break during normal use and foreseeable emergencies, exposing people to hazardous chemicals. They require an SDS.
Consumer Products Used Like a Consumer Would
A consumer product used in a workplace is exempt from SDS requirements only when the duration and frequency of employee exposure matches what a typical consumer would experience at home. If an office worker occasionally uses a can of glass cleaner, that’s comparable to home use. But if a janitor uses that same glass cleaner for hours every shift, the exposure far exceeds normal consumer use, and the employer needs to have an SDS available. The employer carries the burden of proving that workplace use genuinely mirrors consumer use.
Pharmaceuticals in Final Form
Drugs regulated by the FDA are exempt from SDS requirements when they’re in solid, final form for direct administration to a patient (tablets, pills, or capsules) or packaged for retail sale to consumers. However, bulk pharmaceutical ingredients, liquid drugs handled by healthcare workers, and pharmaceutical products during manufacturing or compounding are not exempt. Research institutions that synthesize chemicals and distribute them to other workplaces must also produce an SDS for those materials.
Who Is Responsible for Creating the SDS
The obligation to create and distribute an SDS falls on the chemical manufacturer, importer, or distributor. They must send an SDS with the first shipment of a hazardous chemical and provide updated versions when new hazard information becomes available.
Employers who purchase these products don’t create the SDS, but they are required to keep them accessible to employees during every work shift. That means having a system, whether physical binders or digital access, where any worker can quickly find the SDS for a product they’re using. If an employer has a lab that produces chemicals solely for in-house study, an SDS doesn’t need to be generated for those compounds, as long as SDS information for the component chemicals is readily available on-site to exposed employees.
Recent Updates to SDS Standards
OSHA updated the Hazard Communication Standard in May 2024 to align with Revision 7 of the Globally Harmonized System (GHS), the international framework for classifying chemical hazards. The rule took effect on July 19, 2024, with a multi-year transition period. During this transition, employers can comply with either the previous version of the standard or the updated rule. The core SDS requirement hasn’t changed, but some hazard classification criteria and labeling details have been refined. If you’re managing SDS records, check whether your suppliers have issued updated sheets reflecting the new standard.