Safety Data Sheets for Hazardous Chemicals

The hazard communication standard (HCS) (29 CFR § 1910.1200) requires chemical manufacturers and importers to supply customers with safety data sheets (SDSs) providing users a variety of information about the chemicals, including composition, hazards, and manufacturer or importer contact information. Formerly, this information was provided in the material safety data sheet (MSDS), but a revision to the HCS in 2012 by the Occupational Health and Safety Administration (OSHA) included this name change, as well as some other modifications to the requirements for the document, which will be discussed in detail in this Risk Analysis. For more information about the 2012 update to the HCS, see OSHA's Hazard Communication Standard.

In addition to helping employees understand the chemical risks and hazards in their workplace (and how best to reduce those risks and prevent exposure), the SDS is the first document that employees, emergency responders, emergency physicians, and others turn to for information when there is an accidental release of hazardous materials, such as a chemical spill, a pipeline break, or an industrial accident or explosion. The information contained in an SDS can save lives—and often has. (Lin et al.)

The basic premise of these sheets has not changed with the 2012 HCS update—they should be a one-stop resource for everything an employee needs to know about the potential hazards posed by a chemical product, how to avoid those hazards, and what to do if exposed to that chemical (e.g., first aid, other emergency responses). By requiring employers to make SDSs available to employees, OSHA ensures a worker’s right to know about the hazardous chemicals present in the workplace. The SDS is also used by employers to comply with U.S. Environmental Protection Agency (EPA) right-to-know laws requiring organizations to inform the public about many of the hazardous chemicals in their community. Finally, the SDS is used by emergency responders, firefighters, and emergency physicians to determine how to respond to chemical emergencies and how to handle cases of chemical contamination.

The basic regulatory requirements relating to the SDS are straightforward. OSHA’s HCS requires chemical manufacturers and importers to prepare an SDS for any chemical product that the manufacturer determines to be hazardous and to include the SDS with the product the first time it is shipped to a facility (29 CFR § 1910.1200g). Manufacturers are also under a duty to update the SDS each time more information becomes available and to send the revised SDS to their customers. In most circumstances, an SDS must be updated within three months of notification of “significant” new information about a chemical hazard (OSHA “Hazard Communication; Final Rule”). All employers are required to obtain an SDS for each hazardous chemical product used in the workplace, maintain a complete and...