If you have questions about OSHA’s requirements for maintaining and providing access to Safety Data Sheets (SDSs), you’re not alone. Although the Hazard Communication Standard has been around for decades, understanding what’s required is a headache for many employers.
Yes, OSHA allows you to store SDSs electronically. This means maintaining them on a company website or with an off-site/web-based SDS service provider. It’s not acceptable to require employees to perform an internet search to view or obtain the SDS. Employees must be trained to use the electronic system.
OSHA says that SDSs must be readily accessible to employees during each work shift when they are in their work area. There’s no “distance” requirement, but employees must know the location of SDSs and there must be no barrier to employee access, such as having to ask a supervisor for an SDS or keeping the SDSs in a locked cabinet. If SDSs are kept electronically, employees must be trained to use the system.
The contractor is responsible for maintaining it and for letting you know it’s available if your employees are exposed to the chemical.
If the chemical manufacturer, importer, or employer becomes aware of any significant information regarding the hazards of a chemical, or ways to protect against the hazards, they must add it to the SDS within three months. If the chemical is not currently being produced or imported, the chemical manufacturer or importer must add the information to the SDS before the chemical is introduced into the workplace again.
OSHA says that if you’re maintaining the most recent SDS you received with the shipment of a hazardous chemical, you’re in compliance. If you didn’t receive one, contact the manufacturer, importer, or distributor and request one.
No, OSHA requires that the SDS be specific to the product and manufacturer.
The answers to compliance questions aren’t always clear in the regulations, but OSHA has issued a number of interpretations, frequently asked questions, and other guidance to provide clarity. In addition to regulatory assistance, our experts can often help you find guidance from the many pages of published information. Submit your question through the Expert Help feature in the J. J. Keller® SAFETY MANAGEMENT SUITE and our experts typically respond in a few hours, and no more than one business day.
Sign up to receive the weekly EHS Insider email newsletter for safety articles, news headlines, regulatory alerts, industry events, webcasts, and more.