OSHA SDS Requirements for Employers: A Complete Overview
construction worker

In 2024, OSHA updated its requirements for hazard communication, making it clear that many safety data sheets (SDSs) would need overhauling in the coming months. As these sheets follow OSHA’s Hazard Communication Standard (HazCom), they apply to every U.S. workplace that stores or uses hazardous chemicals and are a key element of workplace safety compliance. With that in mind, how can you ensure that your organization is following the OSHA SDS requirements for employers so that you do not avoid your employer safety responsibilities?

The following guide breaks down your duties in these areas, including:

  • Creating a written plan
  • Taking action to give your employees up-to-date information
  • Creating a digital SDS library
  • Handling multilingual labels
  • Repercussions for not following OSHA safety data sheets law

Read on to simplify your whole compliance process and close any gaps before your next OSHA audit, protecting you and your organization today.

HazCom and OSHA SDS Requirements for Employers

OSHA’s chemical safety regulations include the need to communicate every element of a chemical’s nature that could impact handling or storage. As such, you should make sure that you define these in your employer process documentation.

One of the best things you can do is to create a written program that spells out how your organization’s employees should manage:

  • Chemical labeling procedures and expectations
  • SDS access and oversight
  • Details on how SDS are updated
  • Steps for maintaining a chemical inventory
  • How to review and update your HazCom procedures
  • Up-to-date safety training methods
  • Environmental, Health, and Safety (EHS) rulesets
  • Who and where you procure chemicals from
  • Documentation requirements

If any of these are complicated due to having multiple shift patterns, detail the best ways to overcome these challenges, such as using cloud-based access to data. Also, the list above is not exhaustive, and checking OSHA’s requirements for documentation regarding chemical management is crucial.

The organization’s senior management should also designate the responsibility for creating and overseeing the adoption of this process to a singular individual. Not only will this ensure compliance with duties, but OSHA may ask for this specific point of contact during inspections.

Then, review these steps manually to ensure OSHA compliance and check that your organization’s actions continue to align with internal procedures.

Chemical Hazard Inventorying

Whenever you work with potentially hazardous chemicals, you will need to create a list, documenting each one. The list should include details related to their storage and distribution, such as:

  • Product identification codes and names
  • Container size
  • Location
  • The quantity of a chemical stored

Having this knowledge allows you to not only have a clear understanding of what you have in stock, but also what might be worth disposing of sensibly. You can also use it to identify whether you are storing your chemicals in an area that may be unsafe, as certain chemicals should never remain close to one another or within range of elements such as open flames.

These systems also allow you to make regular, automated reports on the chemicals you handle or manufacture, helping you follow the Toxic Substances Control Act.

Safety Sheet Data Format

One of the key elements in communicating chemical hazards is the use of a 16-section SDS. You should not write these yourself, but should instead check the data on your supplier’s SDS. If you notice something is amiss, such as blank or incorrect fields, you should then contact the supplier to ensure that they rectify the issue.

While many employers still use physical sheets in binders throughout their business, these are both difficult to audit and can easily be damaged or lost. Instead, many organizations now use online SDS systems that can:

  • Automatically update
  • Download offline SDS copies
  • Track who has the latest version
  • Ensure access at all times online
  • Report on access requests

The 16-Section Format

SDS documents mirror the United Nations’ GHS template, allowing for worldwide use. They contain three primary areas of data. These include sections with clear information on:

  1. ID of the chemical and the manufacturer’s contact details
  2. Hazard data and precautionary information
  3. Ingredient percentages
  4. First-aid measures on exposure
  5. Fire-fighting measures related to the chemical
  6. Responding to spills or releases
  7. Storage dangers and handling recommendations
  8. PPE and methods to limit exposure
  9. Properties of the chemical
  10. Stability and reactivity of the material
  11. Toxicology and health effects
  12. Environmental impact of the chemical
  13. Guidance on disposal
  14. Shipping and transportation recommendations
  15. EHS information
  16. Any other information

Although some of these sections are optional, ensuring that you include as much helpful information as possible helps with inspections, including those conducted by authorities other than OSHA, such as the Environmental Protection Agency or the Department of Transportation.

SDS Access for Employees

One of the clear requirements of HazCom is that SDSs need to be available to all employees in their work area at all times. If there is a chance that paper binders may not be available at all times, then this can cause issues should a problem occur. As such, using electronic access may be your best bet for allowing employees unfettered access to SDS data.

Some of the best ways to leverage an online, cloud-based system, such as KHA’s offering, include:

  • Posting QR codes linking to SDS systems at entry points
  • Giving access to temp workers without them knowing the building layout
  • Easy correction of errors with disparate libraries
  • Using alerts to detect when an employee needs to update their copy
  • Storing legacy files offline to prevent data loss without versioning confusion

It is a good idea to keep a backup binder on-site in case of power loss. However, with offline access through smartphones and other devices, this may not always be necessary.

Ensure Compliance Today for Safety Tomorrow

Having a structured HazCom program secures your workers’ safety while also protecting your organization from audits. To help with this, consider using KHA’s Online-SDS platform. It can automate many of the steps related to chemical inventory tracking and the handling of any stored materials, including updating SDS automatically as needed.

To learn what else KHA can do for you and to get the latest on our Online-SDS system, get in touch today. Keep your audits short and uneventful by working with us, and see how simple following OSHA SDS requirements for employers can be.