If you don’t have your safety data sheets (SDS) up to date and available on hand for all employees, then you could be liable for penalty fines for OSHA violations.
Every single hazardous chemical housed at your workplace must have a current SDS indicating safety information on physical and health hazards and how to store, handle and transport the chemicals safely.
These must be stored for 30 years as a hard copy in a file or on a database reachable by all employees.
We’ve compiled this guide on OSHA SDS requirements so you know what’s expected of you to keep employees up to date on the health hazards they’re exposed to. Upholding these practices will ensure your employees’ occupational safety and health.
How Does OSHA Define Hazardous Chemicals?
All hazardous chemicals require a safety data sheet, previously known as MSDSs or material safety
data sheets, so the first step is identifying what OSHA defines hazardous chemicals to be.
Chemicals With Health Hazards
Chemicals are hazardous to health if they can result in:
Chemicals With Physical Hazards
- acute toxicity,
- skin corrosion or irritation,
- severe eye damage or eye irritation,
- respiratory or skin sensitization,
- germ cell mutagenicity,
- carcinogenicity,
- reproductive toxicity,
- specific target organ toxicity, or
- aspiration hazard.
Chemicals pose a physical hazard in the workplace if they are:
- explosive,
- flammable,
- self-reactive,
- pyrophoric,
- self-heating,
- organic peroxide,
- corrosive to metal,
- gas under pressure, or
- in contact with water and emit combustible gas.
If you have any chemicals that pose health or physical hazards at your workplace, OSHA regulations state that you must create an electronic or hard copy file of all SDS documents.
How To Keep Safety Data Sheets as per OSHA Regulations
A chemical manufacturer is responsible for sending an SDS when they deliver a chemical to your workplace for the first time.
But, it’s also your responsibility as the employer to ensure all SDSs are present and up to date.
It’s a good practice for employers to conduct spot tests to verify the chemical inventory and randomly review the master inventory list.
The list should match the labels and SDS identifiers, and the chemical manufacturer should be contacted to ensure the SDS is up to date.
All SDS documents must be housed together in a place that’s easily reachable for any employee. If keeping all documents together electronically is more manageable, this is permitted so long as all employees can easily access the documents.
How To Train Staff Using a Hazard Communication Program For Occupational Safety
A hazard communication plan is a set of processes and procedures documented and then put into place to reduce potential hazards associated with the handling of dangerous chemicals.
The written hazard communication program must contain any SDS covering all hazardous chemicals, and employees must be trained on new hazardous chemicals before they are introduced.
The training must include how to:
- identify each hazardous chemical,
- handle each hazardous chemical,
- store each hazardous chemical,
- transport the chemicals safely, and
- identify the PPE required for the different hazardous chemicals.
The written hazard communication program must explain how to identify and read a safety data sheet.
Safety data sheets have a 16-section format:
- Identification
- Hazard(s) Identification
- Composition/Information on Ingredients
- First Aid Measures
- Firefighting Measures
- Accidental Release Measures
- Handling and Storage
- Exposure Controls/Personal Protection
- Physical and Chemical Properties
- Stability and Reactivity
- Toxicological Information
The following categories are non-mandatory:
- Ecological Information
- Disposal Considerations
- Transport Information
- Regulatory Information
- Other Information
The hazard communication program must indicate where the SDS are located and how employees can access them. This is particularly important if the files are saved electronically. Employers storing SDS electronically must ensure employees have the necessary computer skills to access the documents.
What Are the Penalties for Not Complying With SDS Requirements?
You can rest assured that you’re meeting OSHA requirements if:
- employees know where to find safety data sheets and have ready access to them at all times,
- employees are trained on safety data sheets,
- all safety data sheets are present, and
- all safety data sheets are up to date.
2020 statistics show 3,210 inspections that reported violations of 29 CFR 1910.1200 that resulted in 5,804 citations and fines totalling $3,377,765. Therefore, each fine averaged at $581 per citation or $1,052 per inspection.
How Insure Compliance Can Help
Insure Compliance has a unique Safety Gap Model assessment that employers can undergo to evaluate the gaps in the company that risk the occupational safety of employees.
These safety gaps can be:
- Awareness gap: do you, as the employer, understand the SDS requirements?
- Process gap: do you know how to ensure the SDSs meet OSHA requirements with storing them and ensuring they’re up to date?
- Knowledge gap: are employees trained according to the hazard communication standard?
- Verification gap: are SDSs regularly verified to ensure they’re up to date?
- Accountability gap: are employees held accountable when hazardous materials are not used according to their SDS regulations?
We offer training for employers and employees that meets OSHA’s hazard communication standard.
Insure Compliance’s hazard communication employee training covers:
- how to use different methods to detect the presence or release of a hazardous chemical in the workplace,
- physical and health effects of different chemical hazards,
- protective measures such as appropriate PPE, and
- details of the hazard communication program.
Key Takeaways
All hazardous chemicals in the workplace pose a health risk to employees. Therefore, OSHA’s standards call for an up to date 16-category SDS that indicates safety information on:
- physical hazards,
- health hazards,
- PPE required,
- how to store,
- how to handle, and
- how to transport the chemicals safely.
The SDS must be kept on-site where it’s readily accessible by all employees, whether digital or hard copy.
Employee training must be performed, so employees understand the hazard information documented on the SDSs.
A hazard communication program must be compiled, and employees are to be trained on the safe handling of hazardous chemicals.
If you want to avoid OSHA penalties for not being compliant, contact us today, and we can assist with SDS verification and employee training to ensure occupational safety and health.
Disclaimer:
Please note that every effort has been made to ensure that the information provided in this guide is accurate. You should note, however, that the information is intended as a guide only, providing an overview of general information available to businesses. This guide is not intended to be an exhaustive source of information and should not be seen to constitute legal, safety or business advice. You should, where necessary, seek your own advice for any issues raised in your affairs.
3 Responses
Hello,
Thank you Nat Carroll for the helpful guide. I am verifying our SDS compliance in my workplace and am curious about items not required to meet OSHA requirements. I am finding items such as Windex, Compressed Air, White-Out, Dawn Dishwashing Detergent, Formula 409, Lysol Multi Surface Cleaner, Semi-Gloss Interior Paint, ABS Based 3D Printer Filament, and Air Freshener as examples of questionable items we maintain Data Sheets on but do not incorporate in our normal work process.
I also have ran across a number of items that were probably used one time such as Prestone DOT 3 Brake Fluid, Concrete Bonding Adhesive, 2 cycle Motor Oil.
If an item is used once and is not part of the machinery maintenance or production process it seems foolish to maintain a current SDS when it was gone 5 years ago.
There is no Pass/Fail list of items but we have for instance Powder Coat Paint that needs to be included and we have wall paint (gallons to paint the office) that don’t.
In the past, to be safe we saved everything. Maintaining “everything” is another thing. I want to do what is right but I have seen SDSs for water and compressed air.
Thanks, Brian
Hello Brian!
Many times it depends on the limits of what you have 🙂 IT can be tricky trying to figure this all out!
Thanks,
Nat
Conducting ongoing emergency response drills and giving workers access to important materials is something that is very important in terms of safety. Given that during an emergency every second counts, the process of practicing rescue is quite necessary.