An SDS must be available to workers for as long as the chemical is in use. Once a product leaves your workplace, keep the SDS on file for 30 years from its last date of use. This article covers both rules and what to do when a supplier sends an updated version.
How Long Must an SDS Be Kept According to OSHA
OSHA has two separate rules for SDSs. One covers the time a chemical is in use. The other kicks in after you stop using it. For any chemical currently on site, both rules apply at the same time.
While the Chemical Is in Use
29 CFR 1910.1200, the Hazard Communication Standard, requires employers to keep a current SDS for every hazardous chemical on site. Workers must be able to get to it on every shift without any barriers.
"Available" means exactly that. The SDS needs to be within reach during the work shift. Not locked in a manager's office, and not behind a password. Paper binders work fine. Digital systems work too. Any employee should be able to pull up any SDS right away, even during a power or internet outage.
If a worker asks for an SDS and you can't hand it over, that's a citation under 1910.1200. There's no grace period.
After You Stop Using the Chemical
When a product leaves your workplace, the day-to-day access rule ends. A longer-term one takes over.
Employee Exposure Record: Under 29 CFR 1910.1020, an SDS counts as an employee exposure record once you stop using a chemical. OSHA requires those records to be kept for 30 years from the last date of use.
The 30-Year Clock: It starts on the last day any worker was exposed to the chemical. It doesn't restart when you clear the product from your shelves or storage.
What You Need to Keep: The SDS itself covers the requirement. If holding every SDS for decades isn't workable, OSHA allows a simpler record that names the substance, says where it was used, and covers the dates of use.
The Simpler Record Trap: Many workplaces go this route but forget to write down those details before throwing away the original SDS. Once it's gone, that information is usually gone too. The safer move is to keep the SDS.
What to Do When You Get an Updated SDS
Suppliers send out new versions when a product's formula changes or new safety information comes in. When that happens, you can't just file the new one and toss the old.
- Compare the two versions. Check whether the hazardous ingredients listed have changed.
- If the formula is the same, the new SDS replaces the old one. You can throw out the old version without any 30-year requirement applying.
- If the formula changed, you need to keep both. Each one covers a different period of worker exposure. Hold both for 30 years from the last day the original formula was in use.
- Write the date on every archived version. The dates it was active are what make it useful as a record. A pile of undated old SDSs doesn't help much if a regulator or attorney comes asking.
- Don't discard on the day the new one arrives. Move the old version into your archive the same day the new one goes into use.
Who Keeps What Across the Supply Chain
Where you sit in the supply chain determines what you're responsible for and when.
| Role | SDS Obligation | Retention Period |
|---|---|---|
| Employer (Chemical User) | Keep current SDS available while in use; archive when discontinued | 30 years from date of last use |
| Manufacturer | Write and keep accurate SDSs; update within 3 months of new hazard data | Keep current; own worker records follow 30-year rule |
| Importer/Distributor | Send current SDS to customers at point of sale; send updates when they come in | Must supply updated SDS at each sale; internal employee records follow 30-year rule |
One thing to watch: sell an imported chemical under your own name and OSHA treats you as the manufacturer. That means you take on the responsibility of writing the SDS and keeping the supporting data.
Building a System That Handles Both Rules
Keeping SDS records in order across their full life, from active use through a 30-year archive, takes some planning. Current sheets need to be easy for workers to reach. Archived sheets need safe storage, but they don't need to be part of daily operations.
The step that gets skipped most often is writing down the last-use date the same day a product leaves service. If you wait, the date gets lost. Without it, you can't prove when the 30-year clock started, and your archive won't hold up if it's ever questioned. For larger inventories, a dedicated SDS management system tracks version history and use dates automatically. Cloud-backed storage also means one failed hard drive won't erase years of records.
Two other things to sort out early. If the business is sold, all exposure records go to the new owner. If it closes with no one to hand them to, they go to the Director of NIOSH. Also, file formats don't last forever, so plan to update your archived files every few years. A PDF saved in 2001 may not open in 2031.
Final Thoughts
SDS retention has two parts. The first is keeping a current SDS available for every chemical you're using right now. The second is holding onto records for 30 years after the last time a chemical was used on site.
Start by checking your current chemical inventory against your SDS files. For anything you've stopped using, make sure a last-use date is written down and the SDS is in your archive. If a supplier changed the product formula at any point, you need both the old and new versions. Go through your discontinued chemical list this month and see which ones are missing a last-use date. That's where most gaps show up. And it's the kind of gap that causes problems when a former worker files a health claim years later.
Frequently Asked Questions
Does the 30-year rule apply to chemicals used only occasionally?
Yes. It applies to any chemical that workers were exposed to, no matter how often. Even occasional use creates a record-keeping requirement.
Can you keep SDSs digitally to meet the 30-year rule?
Yes. OSHA accepts digital records as long as they can be pulled up when needed. Workers need access during their shift, and OSHA inspectors need access when they ask.
What if your supplier closes and you can't get old SDSs?
The responsibility stays with you. Fall back on the simpler record: write down the chemical name, where it was used, and the dates.
Do you need to keep the SDS for a product you got but never used?
If no workers were exposed to it, the exposure record rule doesn't apply. The active-use rule under 1910.1200 doesn't apply either if the product was never actually used.
How long must a safety data sheet be kept after a worker leaves?
The 30-year period follows the chemical, not the person. The clock runs from the last day of use regardless of when the worker left.
Zarif Ahmed
An engineer and safety writer by profession, focusing on chemical management, regulatory development, and the patterns that shape workplace practice over time.