Will Your SDSs Make the Grade When OSHA Comes Calling?

Rachel Krubsack, Editor - EHS

April 30, 2024

Employee Reading Chemical Label

During an OSHA inspection, compliance officers are likely to look at your Hazard Communication program, even if that’s not the reason they’ve showed up at the door. What does this mean for Safety Data Sheets (SDSs)?

First and foremost, employers must have an SDS for each hazardous chemical they use, and it must be specific to the product and manufacturer. So, if you have solvents or gasoline from different manufacturers, for example, be sure you have the appropriate SDS. Compliance officers will review a representative number of SDSs against your company’s chemical inventory.

SDSs may be maintained in paper form or electronically on a company website or with an off-site/web-based SDS service provider. If SDSs are stored electronically, employers must have a backup system in place in the event of a power outage or equipment failure.

Employers must maintain the most current version of the SDS provided by the manufacturer, importer, or distributor. There’s no requirement to seek out an updated version of an SDS.

SDSs must be in the 16-section format. Two items of note: Section 1 must contain a U.S. address and contact information. Sections 12-15 are under the jurisdiction of other agencies, like EPA and DOT, so for OSHA’s purposes, those sections don’t have to be filled out, though the headings must be present.

If you’ve contacted the manufacturer, importer, or distributor to request an SDS – whether it’s because you didn’t receive one or because you’ve received one with obvious inaccuracies – be sure to document it. This could be an email, letter, or documentation of a phone call. This shows you’ve made a good faith effort to obtain an SDS.

Employers assume no responsibility for the content and accuracy of the SDS provided to them by the manufacturer, importer, or distributor, unless the employer changes the SDS.

SDSs must be in English, though employers can maintain other languages as well to aid in worker comprehension and training. Employers should ensure that information from the SDS is available to employees in a manner they would understand easily in case of emergency.

And finally, employees must be trained to read, understand, and use the information contained in SDSs, and how to access them.

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