Safety Data Sheets inform employees about the hazards of the chemicals in their workplace, how to obtain information on chemicals, and what to do if a spill or accident occurs with those chemicals in order to provide a safe, secure workplace. The information contained on each SDS also enables organizations to better understand the chemicals they use and how those substances impact the environment. Constant communication of SDS updates to staff is a vital way to promote a positive safety culture in any company. It creates a safer, more informed environment for employees. Changes to SDS can impact the handling or transport of material, as well as disposal methods, and the potential health hazards to employees.

What OSHA regulations require SDS?

The OSHA Hazard Communication Standard (OSHA, 29 CFR 1910.1200(g) and Appendix D) requires manufacturers and importers of a new hazardous chemical to obtain or develop safety data sheets. From there, the manufacturers, suppliers, and distributors are responsible for passing that information along as the product moves through the supply chain. Those entities also are required to update existing SDS as new information becomes available regarding identification, handling, and spill response of hazardous chemicals. This applies to every hazardous chemical they produce or import. The HCS requires that SDSs be updated by the chemical manufacturer or importer within three months of learning of "new or significant information" regarding the chemical's hazard potential. The downstream or end users are responsible for the use and maintenance of SDSs, including accessibility to the most recent version of SDSs for all employees. Users can request updated SDS information from the original supplier or manufacturer. All along the supply chain, employers must provide training to employees regarding how to access an SDS and communicate changes to employees in a timely manner.

What other mandates require SDS?

The U.S. EPA also has regulations that address SDSs. These documents were a requirement under the Clean Water Act of 1970 and the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) of 1980.  Subsequently, these were reaffirmed under the Superfund Amendments and Reauthorization Act (SARA) section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA), which is also known as Title III. Many state and local environmental and safety agencies have a number of regulations that may redundantly require SDSs. Most corporate safety and environmental protection programs also rely on SDSs to educate and inform workers about dangers in the workplace.

What are the dangers of an outdated SDS?

If a manufacturer chooses not to maintain up-to-date SDS documents on file, they are denying their staff valuable information about specific chemicals substances and how to safely handle them. This puts employees at risk and could lead to workplace incidents and injuries or environmental damage. In addition, OSHA or EPA inspectors have the authority to issue violations and assess fines for non-compliance with SDS-related regulations.

Further Information

With Cornerstone’s Foundation SDS Management and Chemical Inventory System, our Chemical Management team do the work for our clients to ensure that their SDS are regularly updated.  For a free demo, visit our website at https://www.cornerstone-ehs.com/demo/ Yabelin Batista has been with Cornerstone since 2019. She is a member of the Chemical Management department at Cornerstone, Environmental, Health and Safety. One of her main responsibilities consists of sourcing and updating current Safety Data Sheets (SDS) for a wide array of products in our Foundation SDS Management and Chemical Inventory System. Her efforts help ensure our customers have the latest documents available.