SDS and HazCom Requirements Under OSHA: A Practical Guide

What are the SDS and Hazard Communication (HazCom) requirements under OSHA?

OSHA's Hazard Communication Standard (HCS), found at 29 CFR 1910.1200, exists so that workers exposed to hazardous chemicals have the information they need to protect themselves. The standard is aligned with the Globally Harmonized System of Classification and Labelling of Chemicals (GHS), which standardized how hazards are classified, labeled, and documented across the world.

At its core, the standard places five obligations on employers whose workers may be exposed to hazardous chemicals: maintain a written hazard communication program, keep a Safety Data Sheet (SDS) for each hazardous chemical, make those SDSs readily accessible to employees during every work shift, label containers according to GHS, and provide employee information and training. The sections below break down each obligation and how the pieces fit together.

What is the written hazard communication program?

The written program is the document that describes how your workplace meets the HazCom requirements. It must address how you handle labels and other forms of warning, how you maintain and provide access to Safety Data Sheets, and how you inform and train employees. It also must include a list of the hazardous chemicals known to be present in the workplace, identified in a way that lets a reader cross-reference each one to its SDS. The written program is meant to be a living document that reflects what is actually happening in your facility, not a binder that sits untouched.

What counts as a hazardous chemical, and what is the chemical inventory?

Under the standard, a hazardous chemical is any chemical classified as a physical hazard or a health hazard, as well as certain other categories such as simple asphyxiants, combustible dust, and pyrophoric gases. In practice this captures a wide range of everyday products, from solvents and adhesives to cleaning agents and compressed gases. The chemical inventory list is the roster of those hazardous chemicals present at the worksite. It anchors the rest of the program because each listed chemical should have a corresponding SDS and appropriately labeled containers.

What is a Safety Data Sheet and what are the 16 sections?

A Safety Data Sheet is the detailed reference document that chemical manufacturers, importers, and distributors must provide for each hazardous chemical. Under the GHS-aligned standard, every SDS follows the same standardized 16-section format and presents the sections in a consistent order, which makes information faster to locate in an emergency. The 16 sections are:

1. Identification — product identifier, recommended use, and supplier contact information
2. Hazard(s) identification — classified hazards, signal word, and label elements
3. Composition / information on ingredients — chemical identity and ingredient concentrations
4. First-aid measures — symptoms and required treatment by route of exposure
5. Fire-fighting measures — suitable extinguishing media and special hazards
6. Accidental release measures — spill containment and cleanup procedures
7. Handling and storage — safe handling practices and incompatibilities
8. Exposure controls / personal protection — exposure limits, engineering controls, and PPE
9. Physical and chemical properties — appearance, odor, flash point, and similar data
10. Stability and reactivity — chemical stability and conditions to avoid
11. Toxicological information — routes of exposure and health effects
12. Ecological information (non-mandatory under OSHA enforcement)
13. Disposal considerations (non-mandatory under OSHA enforcement)
14. Transport information (non-mandatory under OSHA enforcement)
15. Regulatory information (non-mandatory under OSHA enforcement)
16. Other information — including the date of preparation or last revision

OSHA requires Sections 1 through 11 and Section 16 to be completed; Sections 12 through 15 are addressed by other agencies, so OSHA does not enforce their content, though manufacturers typically include them.

How accessible do SDSs have to be?

Employers must ensure that Safety Data Sheets are readily accessible to employees in their work area during each work shift. Readily accessible means employees can get to the information without barriers such as needing a password they don't have, asking a supervisor for permission, or waiting for someone to retrieve a binder from another building. SDSs may be kept in paper or electronic form, but if you use an electronic system you must have a reliable backup and a plan for power or system failures so access is never interrupted.

What has to be on a GHS container label?

Containers of hazardous chemicals shipped from a manufacturer, importer, or distributor must carry a label with six elements. Together these give a worker an at-a-glance summary of the hazard and how to handle it:

• Product identifier — the chemical name or identity used on the SDS
• Signal word — either "Danger" or "Warning" to indicate relative severity
• Hazard statement(s) — standardized phrases describing the nature of the hazard
• Pictogram(s) — the red-bordered diamond symbols representing hazard classes
• Precautionary statement(s) — recommended measures to minimize or prevent adverse effects
• Supplier information — name, address, and telephone number of the responsible party

Workplace containers into which chemicals are transferred must also be labeled, though employers have some flexibility in the format they use for in-house labeling as long as workers are informed of the hazards.

What training do employees need?

Employees must be informed and trained on hazardous chemicals in their work area at the time of their initial assignment and whenever a new chemical hazard they have not previously been trained on is introduced. Training should cover the requirements of the standard, the operations where hazardous chemicals are present, how to read labels and SDSs, the physical and health hazards of the chemicals, and the protective measures available. The goal is practical understanding, not memorization of a binder.

Do SDSs expire, and how long must records be kept?

Safety Data Sheets generally do not carry a mandated expiration date. Instead, the obligation is to keep them current: when a manufacturer becomes aware of significant new information about a chemical's hazards, the SDS and label must be updated within the timeframe the standard specifies, and employers should obtain the revised SDS. The practical takeaway for employers is to periodically verify that the SDS on file is the most recent version available from the supplier.

Retention is a separate consideration. While the HazCom standard itself does not impose a long retention period for SDSs, records that document employee exposure to hazardous substances are governed by 29 CFR 1910.1020, Access to Employee Exposure and Medical Records, which sets long retention requirements and gives employees and their representatives a right of access to those records. Because an SDS can serve as a record of the identity of a substance an employee was exposed to, many employers retain superseded SDSs rather than discarding them.

What about construction work?

Construction employers are not exempt. The construction standards incorporate the Hazard Communication Standard by reference at 29 CFR 1926.59, which adopts the requirements of 1910.1200. In practical terms, the obligations are the same on a construction site: a written program, SDSs for hazardous chemicals, accessibility, GHS-compliant labels, and employee training.

Putting it into practice

A defensible HazCom program ties together a maintained chemical inventory, a current SDS for every listed chemical, accessible storage of those SDSs, compliant labeling, and documented training. The administrative burden grows quickly as your chemical list grows, which is where centralized SDS management software helps you keep the inventory and the sheets in sync. Software that organizes and surfaces this information is a support tool: it does not by itself make an organization compliant, and any program documentation or AI-assisted output should be reviewed by a qualified safety professional before you rely on it. This article is educational information about OSHA requirements and is not legal advice; consult OSHA's regulations and a qualified professional for guidance specific to your workplace.