About SDS
- What is an SDS?
OSHA includes Definitions in Section c of the Hazard Communication(Section c). "Safety data sheet (SDS)" means written or printed material concerning a hazardous chemical that is prepared in accordance with paragraph (g) of this section (i.e., Section c). Paragraph g describes content that must be included. Refer to
http://www.osha.gov/dsg/hazcom/HCSFinalRegTxt.html for more details.
- Why do I need to know about SDS?
If you are an employer, you are required to make Safety Data Sheets available to your employees in accordance with OSHA's Hazard Communication Standard. If you are an employee who works with hazardous chemicals in the workplace, your employer is required to establish a Hazard Communication Program and train you about those chemicals.
- What is the Hazard Communication Standard (HCS)?
- What does RTK mean?
RTK stands for Right-to-Know, and many people use the term Employee Right-to-Know Law in place of the Hazard Communication Standard. The wording comes from OSHA, who describes the purpose of the standard being based on employees having the "right-to-know" the hazards and identities of the chemicals they may be exposed to in their work environment.
- Who determines if a product needs an SDS?
Paragraph (g)(1) of the standard states: Chemical manufacturers and importers shall obtain or develop a safety data sheet for each hazardous chemical they produce or import.
- What information is required to be included on an SDS?
Each SDS is required to have 16 sections, including the following. More details about the content required in each section can be found in Appendix D of the standard (
http://www.osha.gov/dsg/hazcom/hazcom-appendix-d.html).
- Section 1, Identification;
- Section 2, Hazard(s) identification;
- Section 3, Composition/information on ingredients;
- Section 4, First-aid measures;
- Section 5, Fire-fighting measures;
- Section 6, Accidental release measures;
- Section 7, Handling and storage;
- Section 8, Exposure controls/personal protection;
- Section 9, Physical and chemical properties;
- Section 10, Stability and reactivity;
- Section 11, Toxicological information;
- Section 12, Ecological information [non-mandatory];
- Section 13, Disposal considerations [non-mandatory];
- Section 14, Transport information [non-mandatory];
- Section 15, Regulatory information [non-mandatory]; and
- Section 16, Other information, including date of preparation or last revision.
OSHA will not be enforcing information requirements in sections 12 through 15, as these areas are not under its jurisdiction.
- Who decides what other information should be included in an SDS?
The manufacturer or importer of the product.
- Will all SDS look the same?
Unlike the MSDS they replace, all SDS must have the same 16 section format. In addition, content of each section will be more standardized. You may still see some variation in organization of information within sections and some manufacturers or importers may elect to include additional information while others do not.
Employee Access to SDS
- Does OSHA allow for electronic access to SDS?
Yes, electronic systems are permissible as long as there are no barriers to an employee having access. For instance, if your electronic system requires the use of a computer, the employee must have access to a computer as well as any usernames or passwords necessary to access the computer or sds system.
- What does OSHA mean when they say my employee access must be readily available?
There can be no barriers to access. This was a requirement of the previous standard and remains a requirement of the updated standard. Employees should be trained on how to access the information and to understand what they are reading. OSHA has refrained from putting an exact timeframe on how long it may take an employee to obtain the information.
Managing SDS
- How often do I need to update my SDS?
The manufacturer or supplier of products you buy is responsible for sending you an SDS with your initial product shipment, updating SDS as required, and sending you updated SDS with the first shipment after a significant change has been made to the SDS. Employers must ensure SDS for applicable products have been received and filed in a manner allowing immediate access to employees. Employers should include procedures in their written Hazard Communication Program explaining how they handle the receipt of SDS’s to ensure that the most current versions received are available to their employees.
- Can I keep other documents in place of an SDS?
These items may be retained but cannot replace the SDS unless they contain all of the required elements of an SDS.
- Does every product need an SDS?
No, some products are exempt from the HCS. Only hazardous chemicals used in the workplace are covered. Paragraph (b)(6) of the standard (
http://www.osha.gov/dsg/hazcom/HCSFinalRegTxt.html) defines exempt products. They include things like food and cosmetics intended for employee consumption in the workplace, drugs sold in final packaged form (e.g., tablets or capsules) for delivery to a patient, tobacco or tobacco products, and consumer products for which the employer can show that use in the workplace is for the purpose intended by the chemical manufacturer or importer of the product, and that use results in a duration and frequency of exposure which is not greater than the range of exposures that could reasonably be experienced by consumers when used for the purpose intended.
- Who is responsible for sending me the SDS?
The supplier or distributor who provides you with the product. If you do not receive a copy or if you need another copy, the supplier or distributor is required to provide one to you.
- Do I have to keep all the SDS that are sent to me?
You only have to keep SDS for hazardous products. However, many employers keep SDS, even for non-hazardous materials, since it is sometimes easier to keep such documents than to maintain a list of products not requiring an SDS or repeatedly explain why an SDS is not required for certain products.
- If I obtain the same chemical from multiple suppliers, do I need an SDS from each manufacturer?
Yes. The HCS puts the responsibility of providing a SDS on the supplier of the product. That SDS must have the name, address, and phone number of the supplier.
- What is Cooperative Updating?
SDS Access updates safety data sheets in 3 ways:
- You send us updated SDS when you receive them from your supplier
- Another SDS Access customer sends an updated version of an SDS for a product you have in your inventory
- SDS Access staff find updated SDS for the most common products used in our global database
- How long do I need to keep an SDS after we discontinue use of the product?
Employee exposure records, which include SDS or an inventory of the SDS that an employee may have been exposed to, must be kept for 30 years after an employee leaves the organization.