Safety data sheets (SDSs) are required whenever a hazardous chemical is present in a workplace. Under OSHA’s Hazard Communication Standard (29 CFR 1910.1200), chemical manufacturers and importers must create an SDS for every hazardous chemical they produce or bring into the country, and employers must keep those sheets accessible to any worker who might be exposed. The requirement kicks in along the entire supply chain, from the company that makes the chemical to the employer whose workers handle it.
What Counts as a Hazardous Chemical
OSHA defines a hazardous chemical as any substance classified as a physical hazard, a health hazard, a simple asphyxiant, combustible dust, or a “hazard not otherwise classified.” That definition is broad by design. A physical hazard includes anything explosive, flammable, oxidizing, self-reactive, pyrophoric, corrosive to metal, or pressurized. A health hazard covers chemicals that cause acute toxicity by any route of exposure, skin or eye irritation, respiratory sensitization, cancer, reproductive harm, organ damage, or aspiration danger.
Simple asphyxiants, substances that displace oxygen and can cause suffocation, also trigger the SDS requirement. So does combustible dust, meaning finely divided solid particles that can cause a flash fire or explosion when dispersed in air. If a chemical poses an adverse effect identified through scientific evaluation but doesn’t fit neatly into the standard hazard categories, it still qualifies under the catch-all “hazard not otherwise classified” designation. In practical terms, if a chemical in your workplace could hurt someone through normal use or foreseeable misuse, it almost certainly needs an SDS.
Who Must Provide an SDS
The obligation starts with manufacturers and importers. They must evaluate the scientific evidence on every chemical they produce or import and create a compliant SDS. That sheet must be sent to commercial customers before or with the first shipment of the chemical, and again whenever the SDS is updated.
Distributors are required to pass SDSs along to downstream employers. Retail distributors have a slightly different obligation: they must post a sign or otherwise let commercial buyers know that an SDS is available, and provide it on request. The key distinction here is that OSHA’s Hazard Communication Standard does not apply to consumers. If you buy a bottle of cleaning solution at a store for personal use, the retailer has no obligation to hand you an SDS. But if a janitorial company buys that same product in bulk for workplace use, the rules apply.
Employer Obligations at the Workplace
Once a hazardous chemical arrives at a workplace, the employer takes on responsibility. You must maintain a copy of the SDS for every hazardous chemical on site and make sure workers can access it immediately during their shift. Paper binders in a central location have been the traditional approach, but OSHA allows electronic access, microfiche, or any other format, with one condition: no barriers to immediate access. If your digital system goes down, or workers need a password they don’t have, or the computer is in a locked office, that’s a violation.
Laboratories follow a related but slightly different standard. Labs must keep any SDS that arrives with incoming chemical shipments and ensure those sheets are readily available to lab employees. The separate laboratory standard (29 CFR 1910.1450) governs lab-specific protocols, but the core SDS accessibility requirement remains.
Products That Are Exempt
Not everything in a workplace needs an SDS. The exemptions are narrower than most people expect, but they exist.
- Consumer products used as intended: If a product is used in the workplace the same way a consumer would use it at home, with similar frequency and duration of exposure, no SDS is required. The classic example is correction fluid used to fix an occasional typo. But if that same correction fluid is used to blank out entire pages of text, the exposure profile changes and an SDS becomes necessary.
- Articles: A manufactured item formed to a specific shape, whose function depends on that shape, and that doesn’t release more than trace amounts of a hazardous chemical under normal use. This exempts things like desks, computers, and tools.
- Unprocessed wood and lumber: Plain lumber that isn’t being sawed, milled, or otherwise processed is exempt. Treated lumber, however, requires an SDS even when it’s just sitting in storage.
- Drugs in final form: Medications packaged for retail sale, drugs intended for personal employee use at work, and first-aid supplies like aspirin are exempt.
- Tobacco products: Exempt from SDS requirements entirely.
- Biological hazards, ionizing and non-ionizing radiation: These fall under different regulatory frameworks.
- Hazardous waste: Regulated by the EPA rather than OSHA’s Hazard Communication Standard.
The 16-Section Format
Every SDS must follow a standardized 16-section format aligned with the Globally Harmonized System (GHS). This isn’t optional. The sections cover identification, hazard classification, composition, first-aid measures, firefighting measures, accidental release procedures, handling and storage, exposure controls, physical and chemical properties, stability and reactivity, toxicological information, ecological information, disposal considerations, transport information, regulatory information, and other relevant data.
The first two sections are the most immediately useful for workers: they identify the chemical and spell out its hazards in plain terms, including signal words, hazard statements, and pictograms. Sections 12 through 15 cover environmental and transport information that OSHA doesn’t enforce directly but that other agencies (like the EPA and Department of Transportation) require, which is why they’re included in the standardized format.
How Long to Keep SDSs on File
OSHA doesn’t require you to keep outdated SDSs forever, but there’s an important record-retention rule. Under 29 CFR 1910.1020, you don’t have to retain old safety data sheets for any set period, as long as you keep a record of the chemical’s name, where it was used, and when it was used for at least 30 years. That 30-year rule exists because some chemical exposures cause health effects that don’t appear for decades, and workers or their doctors may need to trace past exposures.
In practice, many employers simply keep all SDSs indefinitely rather than maintaining a separate chemical identity log. Either approach satisfies the requirement.
Requirements Outside the United States
If you operate internationally, SDS requirements exist in most industrialized countries but vary in their triggers and format details. In the European Union, the REACH regulation governs when SDSs must be provided. The EU requires SDSs for substances classified as hazardous, as well as for substances that are persistent, bioaccumulative, and toxic (PBT) or very persistent and very bioaccumulative (vPvB). The 16-section GHS format is used in both the U.S. and EU systems, which simplifies compliance for companies shipping chemicals across borders, though specific content requirements differ between jurisdictions.
Canada, Australia, Japan, and many other countries have adopted GHS-aligned SDS requirements with their own regulatory nuances. If you’re shipping hazardous chemicals internationally, the SDS must comply with the regulations of every country where the product will be used.