As an employer or safety manager, compliance is at the top of your list. Some of OSHA’s standards are clear and straightforward. Unfortunately, others are not. Often, there is some confusion about OSHA MSDS requirements. How often do MSDS sheets need to be updated?
Today, we’ll look at proper MSDS record keeping and some of the misconceptions out there. Keep reading for more information about OSHA MSDS binder requirements and more!
What Is an OSHA MSDS/SDS?
MSDS stands for Material Safety Data Sheets. You’ll see this shortened to SDS per recent Hazard Communication Standard (HCS) updates. These data sheets are used by importers, distributors, and chemical manufacturers to communicate health effects, hazard evaluation, proper use, storage, risks, and emergency procedures for chemical products.
Sometimes an SDS is a written document; it may also be printed or otherwise digitally expressed. They’re usually collected and stored in a binder.
As an employer, it’s your job to make sure the contents of the binder are up to date. Use Safety by Design’s safety management services for assistance in this area. It’s a tedious project, but it’s certainly necessary for compliance.
Do Safety Data Sheets Expire?
OSHA requires manufacturers/importers to obtain or develop safety data sheets (SDS). This goes for every hazardous chemical they produce or import. They must also provide the SDS for distributors and employers. The SDS must accompany the first shipment of chemicals. Any updated SDS should be sent within three months of any new and significant information regarding the given hazardous chemical.
So, yes, safety data sheets do expire. The expiration depends on the discovery of new and significant information. OSHA doesn’t clearly define what they mean by “new and significant.” It’s assumed that it includes any changes in classification, new hazards, new risk management, and/or new exposure limits.
SDS Update Requirements
Here’s the timeline for OSHA SDS requirements and further labeling. When it comes to updating labels, keep the new and significant information in mind. OSHA requires chemical manufacturers, distributors, importers, and employers to record this new information and communicate it.
When you become newly aware of this information, you must revise the labels. Labels must happen within 6 months of acquiring the new information. Any chemical shipped after that 6-month timeframe must contain the new information. SDS should be modified in 3 months.
Sometimes, the chemical isn’t currently being imported or even produced. In this case, the manufacturer or importer must add this new information to the SDS and labels. This must occur before the chemical is introduced to the workplace again.
If you’re an end-user, how often do SDS sheets need to be updated? You’ll need to update as you receive new information.
How Often Do SDS Need to Be Updated/Replaced?
How often should safety data sheets be updated? And how often do MSDS need to be replaced? It depends on if you’re a manufacturer/supplier or an end-user.
Manufacturers and Suppliers
If you’re a manufacturer or supplier, OSHA has specific SDS requirements. When preparing the sheets, you must ensure the information accurately reflects the scientific evidence behind the hazard classification. If you become newly aware of new and significant information, you should add it. This may include hazards of a chemical or ways to protect against such hazards. All of this should be added within 3 months of awareness.
End-users
If you’re an end-user, you’re responsible for the latest version. And you must ensure that this information is easily accessible for your employees. Ask your supplier or the manufacturer to supply you with the latest version.
Important Note Re: Safety Sheets for Chemicals
Chemical suppliers are expected to review, revise, and update their SDS periodically. They should do this for all the products they sell. As new hazard information is discovered, changes should be made. The same goes for protective measures and when product formulations have been altered.
Remember that once suppliers have updated their SDS, they aren’t required to send the updates to customers immediately.
How Long Do You Keep SDS Sheets?
So, how long do you keep MSDS sheets exactly? SDS files are considered employee exposure records. Even when a chemical is no longer in use, the SDS should be archived/maintained for 30 years.
Contact Safety By Design for Hassle-Free Safety Management Services
OSHA MSDS sheets requirements represent just one piece of your company’s success and compliance. Perhaps it’s time to use Safety By Design’s safety consulting firm in Houston. You’ve been juggling things on your own for too long. We make SDS forms for chemicals easier so you can focus on your business.
Contact Safety by Design today for all your concerns regarding MSDS revision date requirements. We’ll have the answers you seek!
