Updated April 9, 2019
As an employer, compliance is always top-of-mind. Much of OSHA’s standards are very clearly defined and as such, can be easy to follow. There are, however, some misconceptions about updating SDS, like how often OSHA requires manufacturers and suppliers to update their SDS when manufacturers are must send an updated SDS to downstream to their customers and who is responsible for ensuring SDS in the workplace are up-to-date.
As a general rule, chemical suppliers are expected to periodically review, revise, and update the safety data sheets they provide for the products they sell. Changes are made, as necessary, as new hazard information is found, new information about protective measures is ascertained, or changes are made to product formulations. Once they have updated their SDS, they are not required to automatically send the updated SDS to their customers.
It is the employer’s responsibility to ensure the SDS in their binder are up-to-date.
Here are three frequently asked questions regarding the update of SDSs to keep you compliant.
How often does OSHA require manufacturers/suppliers to send updated SDS to their customers?
Under the Hazard Communication Standard (29 CFR 1910.1200), OSHA requires manufacturers and importers to obtain or develop SDSs for each hazardous chemical they produce or import. Manufacturers and importers must provide these SDSs to distributors and employers “ … at the time of the first shipment of the chemicals, and with the next shipment after the SDS is updated with new and significant information about the hazards.”
As for updating labels with new, ‘significant information,’ OSHA says, “Chemical manufacturers, importers, distributors, or employers who become newly aware of any significant information regarding the hazards of a chemical shall revise the labels for the chemical within six months of becoming aware of the new information, and shall ensure that labels on containers of hazardous chemicals shipped after that time contain the new information.”
When do manufacturers/suppliers have to update an SDS?
According to OSHA, “The chemical manufacturer, importer or employer preparing the safety data sheet shall ensure that the information provided accurately reflects the scientific evidence used in making the hazard classification. If the chemical manufacturer, importer or employer preparing the safety data sheet becomes newly aware of any significant information regarding the hazards of a chemical, or ways to protect against the hazards, this new information shall be added to the safety data sheet within three months.”
How often do end-users have to update their SDS?
If you are an end-user, it is your responsibility to use and keep the latest version – and ensure that it is easily accessed by all employees. You can simply ask the supplier or manufacturer to provide it.
A Compliance Partner That Works For You
At GSM, we are constantly communicating with manufacturers to ensure SDSs are always updated. We don’t wait for deadlines but have our own standard and sourcing process for compliance. As your compliance partner, you can rest assured knowing that we are making compliance a top priority so you can focus on your business. Schedule a free demo to see how GSM can help you today!