Below are Frequently Asked Questions (FAQ’s) and answers about Safety Data Sheets (SDS’s), which are required by OSHA's Hazard Communication Standard and Laboratory Safety Standard. Please send any questions or comments to the App State Industrial Hygiene Office.
Q. How do we decide if we even need to keep SDS’s?
A. SDS's must be kept for all chemical products except those which meet ALL of the following criteria:
General household or office product
Used for its intended purpose
Used in small quantities
Used in a manner that is incidental to your work (i.e. infrequently, for short periods of time, and not one of your job duties).
If in doubt, get an SDS and/or call the Industrial Hygiene (IH) Office for help.
Q. I know we need to keep SDS's, but how do I get them?
A. The best way to make sure you always have the most current SDS is to either request one before ordering the product or to include a request in your order. Requesting an SDS before purchasing a product allows you to see if that product has hazards you might want to avoid. It may change your mind and guide you towards purchasing a less hazardous alternative. If a manufacturer is unwilling or unable to provide you with either an SDS or a written statement that the product is not hazardous, that is a good indication that you should look for a different item.
If a product arrives without an SDS, you can always contact the manufacturer to request one and in most cases you can find it directly online.
Q. Why doesn't the Safety Office just keep all the SDS's? That way they'd all be in the same place?
A. SDS's for products to which employees may be exposed need to be readily available to those employees so they can stay informed about the hazards in their work area. Paper copies are encouraged in order to maintain accessibility during a network or power outage, but the information can also be maintained in an electronic folder (such as google drive).
For employees whose work is "roaming" in nature, OSHA allows SDS's to be kept in a central location. However, the information on the SDS's must be immediately available to the employee, so there must be a member of staff available by phone in the area where the SDS's are stored at all times during all shifts covered by the department.
Q. We keep our SDS's in the main administrative office. Is that okay?
A. Yes, as long as the SDS's are available to all your employees during all their work shifts. However, it is even better if you can keep the SDS's in the work area where the hazardous products are actually used.
If it is not reasonably convenient to keep SDS's in the area where the hazardous materials are used, it is okay to keep them in a central office, break room, warehouse, or other location as long as that office is accessible to all employees who are exposed to the products during all shifts (i.e. not in a locked room or cabinet).
Q. Why do we have to keep SDS's at the job site?
A. There are two main reasons for this requirement: if you have an injury, spill, or fire, having SDS's readily available will help inform the response actions and could save your life. Additionally, employees should be able to educate themselves about the potential health effects of a product before they use or are otherwise exposed to it.
Q. I work in a laboratory; are there any special SDS requirements that apply to me?
A. Yes. If you ship any chemicals to another party, you essentially become a "manufacturer" in OSHA's eyes, so you must label the container and provide an SDS with the shipment. If a substance is produced in and for exclusive use of the lab, then you do not need an SDS but you do need to determine if it is hazardous and train potentially exposed people accordingly. Don't forget to include items treated with chemicals, such as lab specimens, as well as pure chemicals. If the substance is a reaction intermediate or byproduct whose composition is not known, then SDS's are not required but you must assume it is hazardous. You also should label the secondary container (flask, beaker, etc.) into which you transfer a chemical with the identity of the chemical.
Don't forget that you must make others who might be exposed to the chemicals aware of the hazards and the location of the SDS's (e.g., a plumber working on the pipes, a ventilation contractor working on the hood ductwork). This requirement applies to non-lab workplaces too, but labs are particularly likely to have unusual hazards that should be conveyed to non-lab employees.
Q. I work in a stockroom/warehouse. Do we have to keep SDS's?
A. Yes and no. OSHA gives a break to stockrooms, warehouses, and other places where all chemicals are in sealed containers. You do not have to actively seek SDS's for all products handled in the warehouse. You only have to keep SDS's that arrive with the shipment or any SDS's requested by an employee in the warehouse.
This only applies to products that are in a sealed container, though. If you transfer bulk products to smaller containers, for example, you must have an SDS. Any chemicals you use or may otherwise be exposed to that meet the four criteria in Question 1 also require an SDS.
Q. Do we have to have SDS's for medicines?
A. Probably not, though it depends on the intended use of the medicine and its physical form. It is unlikely that any place other than perhaps Student Health Services would need SDS's for medicines. You do not need an SDS for food, drugs, and cosmetics brought into the workplace for employee consumption.
Q. What do I do if I or a fellow worker is injured or becomes ill, and I suspect it may be because of a chemical product they are using on the job?
A. If it is an emergency, call extension 8000 and get the necessary medical help. Grab the relevant SDS’s and send them with the injured person or give it to the emergency medical personnel (don't delay emergency attention to get the SDS -- you can always send it later). If the victim is incoherent or unconscious, be sure someone indicates which particular SDS's are applicable to the injury. The information in the SDS could save that person's life, or minimize the damage of his/her injuries. If you can transport yourself, bring a copy of the applicable SDS with you.
Q. Keeping up with SDS's sounds complicated. What sort of filing system should I use?
A. It's actually much easier than it sounds.
When a new product arrives, either date the SDS, or add the product and date to your chemical inventory list. Month and year (or even year only if you don't know the month) are sufficient. Make sure you put the date you started using the product, not the date you received the SDS.
Keep current SDS's in an easy-to-find place that all employees can access during all shifts.
When you stop using that product, date it again with "stopped using on [month/year or year only]" and move the old SDS to another folder, binder, or a separate section of the SDS binder. Or, update your chemical inventory list with the date you stopped using the product and discard the out-of-date SDS. Noting the date you begin using and stop using the chemical is important and will help ASU meet OSHA requirements.
One of the simplest and most effective ways to keep SDS's is a 3-ring binder. Some people like to insert each page into a plastic page protector. If you have a lot of chemical products, using tabbed dividers or colored paper to separate them into groups is handy. The best ways to sort SDS's into groups is either by the way the products are used in your area (e.g. cleaning supplies, painting products, welding materials, etc.) or by the location where they are used (e.g. electrical shop, woodworking classrooms, etc.). If a traditional ring-binder notebook is not your style, some people use accordion files, regular filing cabinets, or even computer shared drives or google drive (as long as all affected employees are able to use the computer).
Q. Do I need to save old SDS's?
A. You must either save old SDS's or save the list of chemicals used in your workplace for at least 30 years after you stop using the product.
References
North Carolina Occupational Safety and Health Standards for General Industry Part 1910 (NCOSHA 1910), Section 1200, Hazard communication
NCOSHA 1910, Section 1450, Occupational exposure to hazardous chemicals in laboratories