When are SDSs required?

SDSs are required for each hazardous chemical a manufacturer or importer produces or imports. This includes all substances or mixtures which meet OSHA’s criteria for physical, health, or environmental hazards and for all mixtures which contain ingredients that meet the criteria for carcinogenic, toxic to reproduction or specific target organ toxicity in concentrations exceeding the cut-off limits specified by the criteria for mixtures. Competent authorities may also require SDSs for mixtures not meeting the criteria for classification but containing hazardous ingredients in certain concentrations.

With the revision to the Hazard Communication Standard, SDSs now have a standardized 16-section format and minimum information must be given for each of the 16-sections. What if specific information is not available for a given section?

If specific information is not applicable or not available for a given section, then the SDS must indicate that no applicable information was found.

When a new SDS is received are you required to keep the old SDS?

If the formulation is identical on the new SDS, then you are not required to retain the old SDS. But if the formulation has changed, then you are required to maintain the old SDS.

How long must SDSs be maintained?

Based upon OSHA’s Access to Employee Exposure and Medical Records Standard (29 CFR 1910.1020), employers are required to keep some record of the identity of the substances to which their employees were exposed to for 30-years. OSHA recognizes SDSs as an acceptable record. If you choose not to retain the actual SDS then you must not only have a record of the identity (chemical name), but also information regarding where and when it was used.