Having clear, practical rules on Safety Data Sheets reduce risk and delays. This guide shows when an SDS is needed, who must provide it, and what to do next. It also sets out simple steps for storage, access, and updates. Clear steps support labels, training, and emergency response
When is an SDS required
If a hazardous chemical is known to be present in a way that employees may be exposed during normal use or a foreseeable emergency, an SDS for that substance must be present and readily available, under OSHA’s HazCom. This list below expands upon the scenarios when SDS is required, further:
| Scenario | Brief | Thresholds/conditions | What to do |
|---|---|---|---|
| Hazardous chemical present | A hazardous chemical is present in the workplace. | The chemical is known to be present and workers may be exposed during normal operations or a foreseeable emergency. | Maintain an SDS for each hazardous chemical and keep access immediate in work areas on every shift. |
| First supply to a workplace recipient | Initial shipment of a hazardous chemical to a distributor or employer. | First shipment to a workplace recipient. | Include the SDS at or before that first shipment. |
| First shipment after an SDS update | Significant new hazard or protection information becomes available. | New information affects classification or recommended controls. | Update the SDS within 3 months, then send the revised SDS with the first shipment after the update. |
| Distributor & point-of-sale transactions | Supply to distributors or employers, including counter sales. | Product is supplied for workplace use. | Provide the SDS with the initial and post-update shipment, and make it available on request at purchase. |
| Sealed-container operations (e.g., warehousing) | Containers remain sealed during normal handling. | Potential exposure may occur during leaks or spills. | Keep any SDS received; if one is missing and an employee requests it, obtain it promptly and ensure access each shift. |
| Laboratories | Labs rely on incoming SDS and must share one when shipping out. | Hazardous chemicals are received for use, or shipped to others. | Keep incoming SDS readily accessible; when shipping chemicals, provide labels and an SDS to recipients. |
| Consumer-product situations | Some household-type uses fall outside the requirement. | Use is for the intended purpose and exposure is not greater than typical consumer exposure. | Where exposure stays within consumer range, an SDS may not be required; if it exceeds that range, an SDS is expected. |
OSHA requirements for provision, format, and delivery
OSHA provides guidelines for provision, format, and workflow regarding SDSs. This compact checklist lists the requirements below:
| Requirement / Step | What applies | Quick check |
|---|---|---|
| Timing (initial shipment) | Provide SDS free of charge with the first shipment and with the first shipment after an update. | Was the SDS included with initial and updated shipments? |
| Active transmission | Send the file or include it in the box. Electronic delivery is fine when workers can access it without delay. | Was the file sent or access clearly provided and shared? |
| Language | SDS must be in English under OSHA. Other languages may be added. | Is the English version available for all sites that need it? |
| Structure (Appendix D) | Use the 16-section SDS. Sections 1–11 and 16 are mandatory. Sections 12–15 may appear but are not required under OSHA. | Are all required sections present and dated? |
| Pre-check | Confirm classification, hazard statements, and protective measures. | Do hazards in Section 2 match your labels and training? |
| Initial dispatch records | Keep proof of what you sent and when. | Is there a dated record of transmission? |
| Updates & distribution | Update within 3 months of significant new info. Send the updated SDS with the next first shipment. | Are changes tracked and sent on time? |
| Version & worker access | Employers keep the current SDS and ensure it is readily accessible during each shift. Electronic systems are fine if there are no barriers. | Can workers get the SDS at once in their area? |
| Documentation | Keep prior versions and a distribution trail. | Can you pull the audit trail fast? |
Obligations after initial shipment
When new hazard or protective information becomes available, regulations require that the SDS be updated within 3 months. The revised version accompanies the first shipment after the update. Employers typically replace older copies so the most current version remains readily accessible during each shift.
Ensure access in the company
Employers must maintain SDS and ensure they are readily accessible to employees in each work area on every shift. Electronic access is acceptable. There must be no delay or login barrier.
For remote crews, keep SDS at the primary facility if workers can get the file right away when needed. Keep a simple index of hazardous chemicals that links to each SDS.
Key takeaway to stay compliant
A practical approach is to clarify roles for preparing, transmitting, and maintaining SDS:
- provide them at first supply and after updates
- keep access readily available in work areas
- align labels, training, and records so day-to-day practices match the information in the SDS.
These steps help you keep your workplace safe and remain compliant.
Frequently asked questions (FAQ)
1. Do I have to send a new SDS with every order?
No. Send an SDS with the initial shipment and with the first shipment after an update. Customers can also request an SDS at any time.
2. Is a link on my website enough?
Not by itself. Provide the SDS with the shipment or send it before or at the time of shipment. Electronic workplace access is fine if there are no barriers.
3. When is an SDS required by OSHA for consumer-type products?
If workplace use and frequency exceed typical consumer exposure, HazCom applies and you should have the SDS. If use mirrors consumer exposure, an SDS may not be required for that use.
4. What format must the SDS follow?
Use the 16-section format in Appendix D. Sections 1–11 and 16 are required. Sections 12–15 may be present but are not mandatory under OSHA.
5. How fast must SDS be updated after new information appears?
Within 3 months of learning significant new hazard or protection information. Then provide the updated SDS with the first shipment after the update.