An SDS must be current and accessible to workers for as long as a hazardous chemical is on site. Once a product leaves service, no fixed statutory period applies to SDSs. Retaining them for 30 years from last use is widely recognised best practice for worker exposure records. This article covers both requirements and what to do when a supplier sends through a revised version.
How Long Must an SDS Be Kept According to WHS Regulations
Australian WHS Regulations set out two distinct requirements for SDSs. One applies while a chemical is in use. The other is about how current the SDS needs to be. For any chemical on site right now, both apply together.
While the Chemical Is in Use
Under WHS Regulations (s.344), PCBUs must hold a current SDS for every hazardous chemical in their register. Workers need to be able to access it at all times, with nothing blocking the way.
"Accessible at all times" means exactly that: available in the work area, not locked away or restricted behind a login. Paper copies work fine. Digital systems are fine too. Any worker must be able to retrieve any SDS right away, even during a power outage.
Failure to provide access is a breach of your WHS duties. State and territory regulators, including SafeWork NSW, WorkSafe Queensland and WorkSafe WA, enforce these requirements. There's no grace period.
After You Stop Using the Chemical
When a product leaves your workplace, the obligation to keep it in your active register ends. You then move into best-practice territory.
Worker Exposure History: There is no explicit WHS statutory period for retaining SDSs after a chemical is discontinued. That said, retaining them for 30 years from the date of last use is widely considered best practice, consistent with how long health monitoring records must be kept under WHS Regulation Schedule 14.
Why It Matters: Occupational diseases linked to chemical exposure, such as certain cancers or respiratory conditions, can take decades to appear. An SDS from a product used years ago may be the only document connecting a former worker's health condition to their time at your workplace.
What to Keep: Holding onto the SDS itself is the most straightforward approach. If that isn't workable, a substitute record naming the product, recording where it was used, and covering the dates of use is a reasonable alternative.
The Substitute Record Trap: Many workplaces opt for the substitute but forget to write down those details before removing the original SDS. Once it's gone, that information rarely comes back. The simpler move is to keep the SDS.
What to Do When You Get an Updated SDS
Manufacturers and importers must review and update SDSs at least every five years. Updates may also come through earlier if hazard data changes. When a new version arrives, the old one can't simply be discarded.
- Compare the two versions. Look at whether the hazardous ingredients differ between the old version and the new one.
- If the composition is the same, the new SDS takes over. You can remove the old version from active use without any long-term retention obligation attaching to it.
- If the composition changed, keep both. Each version documents a separate period of worker exposure. Retain both for 30 years from the last date the original composition was in active use.
- Date every version you archive. The period it was in use is what gives it value as an exposure record. A collection of undated old SDSs offers very little to a regulator, a WHS inspector, or a compensation process.
- Don't remove the old version on the day the new one arrives. Transfer it to your archive at the same time the new one takes its place in the register.
Who Keeps What Across the Supply Chain
Your role determines what WHS obligations apply to you and at what point.
| Role | SDS Obligation | Retention Requirement |
|---|---|---|
| PCBU (Chemical User) | Keep current SDS in hazardous chemical register; accessible to workers at all times | Retain for as long as in use; best practice 30 years after last use |
| Manufacturer | Prepare SDS before or as soon as practicable after first manufacturing; review every 5 years | Keep current; update whenever significant new information comes to light |
| Importer/Distributor | Supply current SDS with each hazardous chemical; review at least every 5 years | Must provide updated SDS on each supply; retain own worker records per best practice |
One thing to watch: package or relabel an imported chemical under your own product name. WHS Regulations treat you as the manufacturer from that point. That shifts the responsibility for preparing the SDS and keeping supporting classification data to you.
Building a System That Handles Both Obligations
Keeping SDS records in order across their full lifespan, from active use through a long-term archive, takes some forethought. SDSs in active use need to be in your hazardous chemical register and easy for workers to get to. Archived SDSs need secure storage away from daily operations.
The step most often skipped is noting the last-use date the same day a product leaves service. Leave it too long and that date disappears. Without it, you can't establish when retention started. Your records won't hold up if they're ever reviewed. For larger inventories, a dedicated SDS management system handles version tracking and date records automatically. Cloud-backed storage also means a single hardware failure won't erase years of records.
Two other things to sort out early. If the business changes hands, exposure records should transfer to the new owner as part of the handover. If it closes without a successor, contact your state or territory WHS regulator for guidance on record transfer. File formats don't last forever either, so build a periodic review of your archived files into your schedule. A document saved in 2001 may not open reliably in 2031.
Final Thoughts
SDS obligations under the WHS Regulations have two sides. The first is keeping a current SDS in your hazardous chemical register for every chemical in active use. The second is retaining those records after a product is discontinued. Thirty years from last use is the accepted benchmark for worker exposure documentation.
Check your hazardous chemical register against your actual inventory this month. For anything discontinued, confirm a last-use date is on file and the SDS is stored somewhere accessible years from now. Where a supplier updated the product's composition at any point, you need both versions. Work through your discontinued product list and confirm which ones have a recorded last-use date. That's where most gaps are found. They tend to surface when a former worker files a compensation claim years down the track.
Frequently Asked Questions
Does the 30-year best-practice guidance apply to chemicals used only now and then?
Yes. The exposure history rationale applies regardless of how frequently the chemical was used. Any product a worker handled is worth retaining records for.
Can you keep SDSs digitally to meet your WHS obligations?
Yes. Safe Work Australia permits electronic SDS systems provided workers have immediate access at all times. No barriers during a WHS inspection, and an offline backup for emergencies.
What if your supplier stops trading and you can't obtain old SDSs?
The responsibility to maintain records stays with you. Use the substitute record approach: document the product name, where it was used, and the period of use.
Do you need an SDS for a product you received but never actually used?
If no workers were exposed to the chemical, the exposure record rationale doesn't apply. The active-use obligation also doesn't apply if the product was never put to use in the workplace.
How long should an SDS be kept after a worker has left the workplace?
Retention is tied to the product, not the individual. Best practice is 30 years from the last date of use.
Zarif Ahmed
An engineer and safety writer by profession, focusing on chemical management, regulatory development, and the patterns that shape workplace practice over time.