How Often Does a Safety Data Sheet (SDS) Need to Be Updated, and Who Is Responsible?

Understanding the requirements for updating Safety Data Sheets (SDS) is crucial for anyone managing hazardous chemicals or overseeing workplace safety. This article outlines when SDS updates are necessary and why accurate SDS information is vital for safeguarding employees and ensuring regulatory compliance.

But First: What Is an SDS and Why Is It Important?

An SDS, previously known as a Material Safety Data Sheet or MSDS, is a comprehensive document that provides critical information regarding the handling, storage, and risks associated with a chemical substance. SDSs are essential in workplaces where chemicals are used, stored, or transported, and they serve as a key resource for educating personnel who work with hazardous materials.

Each SDS follows a standardized format, consisting of 16 sections, each providing specific details to ensure safe handling and effective emergency response.

SDS Sections:

1. Identification: Information about the product, supplier, and recommended uses
2. Hazard Identification: Classifications, pictograms, and precautionary statements
3. Composition Information on Ingredients: Chemical ingredients, components, or concentrations
4. First-Aid Measures: Steps to take if someone is exposed to the chemical
5. Fire-Fighting Measures: Guidance on how to handle a fire involving the chemical
6. Accidental Release Measures: Procedures for responding to a chemical spill or leak
7. Handling and Storage: Instructions on safely handling and storing the chemical
8. Exposure Controls/Personal Protection: Safety equipment, Personal Protective Equipment (PPE), and exposure limits
9. Physical and Chemical Properties: Chemical characteristics, such as appearance, boiling point, or pH
10. Stability and Reactivity: Chemical stability and potential hazardous reactions
11. Toxicological Information: Potential adverse health effects
12. Ecological Information: The impact of the chemical on the environment
13. Disposal Considerations: Proper disposal
14. Transport Information: Guidelines for safe transport
15. Regulatory Information: Legal requirements and applicable safety standards
16. Other Information: Additional safety measures or revisions

SDSs are crucial in helping employees identify chemical hazards and providing clear, detailed guidance to minimize risks. They are vital in reducing accidents and injuries.

The Globally Harmonized System (GHS) of Classification and Labeling of Chemicals mandates that an SDS accompany every chemical to ensure consistency and transparency. This enables employers and employees to make informed decisions regarding the use of chemicals in their workplace. SDSs may also recommend safer alternatives or additional precautions to mitigate potential hazards.

Who Is Responsible?

Chemical Manufacturers and Suppliers:
Manufacturers and suppliers must create and maintain SDSs for each chemical product they produce or distribute. Under the Hazardous Substances Act and OSHA regulations, these SDSs must include critical information on chemical hazards, exposure scenarios, and safety measures.

Employers:
Although employers are not responsible for authoring or modifying SDS content, they play a key role in maintaining accessibility and compliance.

Employers must:

• Ensure that the most recent SDSs are readily available to employees.
• Organize an up-to-date SDS library.
• Train employees in safe chemical handling practices.
• Comply with OSHA’s Hazard Communication Standard.

Up-to-date SDSs help prevent workplace incidents, ensure compliance during inspections, and support a safety-oriented workplace culture.

How Often Should SDSs Be Updated?

There is no set schedule for updating SDSs. Manufacturers are required to revise them when:

• New information about a chemical’s hazards becomes available.
• Changes are made to protective measures or safe handling practices.
• Regulatory updates necessitate modifications.

Employer Best Practices

To maintain compliance and ensure employee safety, employers should follow recommended practices:

• Stay in Touch with Suppliers: Proactively contact your chemical suppliers to check for updated SDSs, especially after receiving a new chemical product.
• Regular SDS Reviews: Conduct annual audits of your SDS library to verify that all documents are current and relevant to your workplace. A chemical inventory can help identify missing or outdated SDSs.
• Employee Access: Use electronic management systems to make SDSs accessible. This approach aligns with OSHA’s emphasis on easy access to hazard information.

Consequences of Outdated SDSs

Failing to maintain accurate SDSs can result in significant consequences, including:

• Regulatory Penalties: Non-compliance with OSHA’s Hazard Communication Standard can lead to substantial fines and legal issues.
• Increased Safety Risks: Outdated information may fail to communicate crucial hazard details or protective measures, leading to workplace accidents or chemical exposures.

To minimize these risks, employers could invest in electronic SDS management systems that automatically update information as manufacturers release new versions.

Managing Safety Data Sheets is more than just a regulatory requirement; it is a fundamental aspect of workplace safety. By keeping SDSs accurate and accessible, businesses can minimize risks, ensure compliance with OSHA standards, and promote a safer work environment.

Sources:

https://www.epa.gov/epcra/resubmitting-revised-sdss-based-oshas-new-hazard-communication-standards

http://www.osha.gov/hazcom