Confused About SDS Requirements for Articles?
If you’ve ever been told, “We need an SDS for this product,” only to realize the product is actually an article, you’re not alone. Manufacturers and suppliers run into this confusion all the time.
While OSHA’s Hazard Communication Standard (HCS) clearly exempts articles from Safety Data Sheet (SDS) requirements, many customers and downstream users still request one for reference, due diligence, or training purposes. Let’s look at what the regulation really says, why these requests keep coming in, and how you can manage them efficiently, without manual edits or “SDS hacks.”
What OSHA’s Hazard Communication Standard Actually Says
Under the OSHA Hazard Communication Standard (29 CFR 1910.1200), articles are specifically exempt from SDS requirements. OSHA defines an article as:
“A manufactured item which is formed to a specific shape or design during manufacture, whose end-use function depends on that shape or design, and which does not release more than very small quantities of a hazardous chemical under normal conditions of use.”
In simple terms, this exemption applies to most finished products that maintain their form and do not release hazardous substances during normal use. Items such as batteries, electronics, or metal components typically fall under this category since they do not present the same workplace risks as raw chemicals or mixtures.
So Why Do Customers Still Ask for an SDS?
Even though the rule is clear, the context of how an article is used can change whether safety information is needed.
OSHA has clarified that determining an article’s status must take into account normal use as well as foreseeable emergencies, such as maintenance, processing, or recycling. For example, a lithium-ion battery might be exempt under consumer labeling rules, but it could still require an SDS for workplace handling or distribution.
Beyond regulatory details, many OEMs, retailers, and EHS teams simply want a safety document on file. Having this information available helps with employee training, internal reviews, and quick access to transport, emergency, or disposal guidance.
Because the SDS format is not designed for articles, many manufacturers create an Article Information Sheet (AIS). This is a simplified, SDS-style document that clearly states the product’s exemption. For example:
“This product is an article and is therefore exempt from SDS requirements under 29 CFR 1910.1200(b)(6)(v). The information below is provided for informational purposes only.”
Challenges of SDS Compliance for Exempt Articles
The challenge is that a traditional SDS format is designed for chemicals or mixtures, not finished products. OSHA’s Appendix D outlines what an SDS must include for hazardous chemicals, but it does not provide guidance for articles that are exempt.
As a result, many teams create “courtesy” SDSs or manually edit templates to include article disclaimers. These workarounds often involve copying content into Word and adjusting section headers, which takes extra time and can lead to inconsistencies across product lines.
In short, the system was not built with articles in mind.
Why Most SDS Authoring Tools Make This Hard
Most SDS authoring software focuses on hazard classification, pictograms, and chemical compositions. When you need to create an article-specific information sheet, automation breaks down.
That’s when users get creative, cloning a chemical SDS, deleting sections, and inserting disclaimers like “This product is an article” in Section 1 or 2. Multiply that by dozens or hundreds of SKUs, and you’re left with inconsistent documentation and hours of manual editing.
How TotalSDS Simplifies Article Documentation
At TotalSDS, we believe you shouldn’t have to outsmart your own software just to provide accurate information. That’s why our platform includes a streamlined way to handle article documentation right inside your SDS Manager — no copy-paste required.
Here’s how it works:
- Set the Article Base Statement Once: You can configure a default “Article” statement that automatically populates the correct exemption language in Section 2 of your SDS.
- Scale It Across Your Catalog: Enable auto-apply to include the Article language in all new SDSs by default. You can also extend it to related product families, ensuring consistent compliance and messaging across every SKU.
This eliminates manual edits, reduces the risk of inconsistent data, and helps your team stay audit-ready without leaving the TotalSDS platform.
Example Language for Section 2
For teams creating an Article Information Sheet or an SDS for an exempt article, the following language can be used in Section 2 – Hazard Identification:
“This product is an article as defined in 29 CFR 1910.1200(c) and is therefore exempt from the requirements of the OSHA Hazard Communication Standard per 29 CFR 1910.1200(b)(6)(v). This document is provided for information purposes only to assist downstream users. Certain downstream activities, such as maintenance, processing, recycling, or foreseeable emergencies, may present hazards.”
This example provides a clear disclaimer while maintaining compliance with OSHA guidance and can be applied consistently across similar products.
Simplify Compliance Without Compromise
Customer requests for SDSs on articles aren’t going away, but handling them doesn’t have to mean reinventing your templates or juggling Word files.
With TotalSDS, you can automate article statements, maintain consistency across your documentation, and communicate clearly with customers while staying fully compliant with OSHA’s Hazard Communication Standard.
Learn more about how TotalSDS streamlines SDS authoring for articles and chemicals →
