The Four Key Stakeholders 

Critical Distinction: Employer vs. Manufacturer Responsibilities 

Employers that only use chemicals in their operations generally do not create SDSs. Their duty is to obtain SDSs from suppliers, keep them accessible, and train employees. However, employers that manufacture, import, or repackage chemicals can have both manufacturer and employer responsibilities. For example, a facility that blends chemicals for internal use and also ships them to customers must classify hazards, author SDSs, and transmit them—while also maintaining SDSs for all other chemicals used on-site.  

The HCS 2024 Update and November 2026 Employer Deadline 

OSHA’s May 20, 2024, final rule updates the HCS to align primarily with the UN Globally Harmonized System (GHS) Revision 7. The rule became effective on July 19, 2024, but compliance is phased. The important deadline for the employers in this context is November 20, 2026, wherein all their Safety Data Sheets should be in line with the revised standard for chemicals. This clearly shows how urgent it is for the employers to audit their library of SDSs and reconcile it with the list of their chemicals. 

The Responsibility Chain  

SDS responsibility flows downstream from creation to end-use. Each party has a defined role, and gaps at any point can create compliance exposure. 

How responsibility moves through the supply chain: 

1. Manufacturers/Importers assess each hazardous chemical, classify the hazards according to HCS standards, and develop a 16-section SDS in English. Manufacturers and importers must accompany the first shipment of a hazardous chemical with an SDS and the subsequent shipment of a revised SDS. 
2. Distributors get the SDS from the manufacturer/importer and must make sure that the SDS goes along with all shipments downstream. Distributors don't modify the SDS unless they repack or relabel in such a manner as to change the hazards, in which case the duties of the manufacturer/importer apply. 
3. Employers receive the SDS in the first shipment and keep it, make sure it is always readily accessible to employees in the work area during every shift, and train employees in locating and understanding SDS information. They also must revise their HazCom plan whenever there is new hazard information. 

HCS 2024: What Changed, and When Does It Apply to You? 

The HCS 2024 final rule is the latest update to OSHA’s hazard communication program since 2012. This update harmonizes the requirements in the U.S. to those of GHS Revision 7 by adding new hazard categories, changing classification rules, expanding label flexibility, and modifying SDS information.

Key Changes in the May 20, 2024, Final Rule 

• Effective date: July 19, 2024 

• Primary alignment: GHS Revision 7 (with some deviations) 

• Changes to Hazard Classification: New criteria for existing hazard categories; new hazard categories created (e.g., desensitized explosives, compressed chemicals); new criteria for aerosol hazards and flammable gases 

• Definitions of Terms: Definitions for terms such as combustible dust, flammable liquid, physical hazards, and others 

• Changes to Labeling: Flexibility for small containers (≤100 mL and ≤3 mL); new hazard/precautionary statements; updated bulk shipment label requirements 

• SDS content changes: Section 1 must include a U.S. address; Section 2 requires more detailed hazard descriptions; Section 3 allows concentration ranges to protect trade secrets (aligned with WHMIS); Section 9 adds particle size/shape endpoints; and Section 11 expands guidance on chemical interaction effects  

• January 15, 2026, extension: OSHA extended compliance dates to provide additional transition time 

Current Compliance Deadlines 

OSHA's January 15, 2026, final rule extended the original compliance dates. The current deadlines are 

What This Means in Practice 

1. For manufacturers, importers, and distributors: 

By May 19, 2026, all SDSs and labels for substances must comply with HCS 2024. For mixtures, the deadline is November 19, 2027. During the transition period, suppliers may comply with the 2012 standard, the 2024 standard, or a combination—but once they transition, all SDSs and labels for that product must meet the 2024 requirements.  

2. For employers: 

For all substances in inventory by November 20, 2026, employers are required to ensure that the SDSs conform to the provisions of HCS 2024. The deadline for mixtures is May 19, 2028. Employers should make requests for updated SDSs before they run out, particularly of those substances that they order frequently. For those substances that are not ordered anymore, employers must “pull” the SDSs anyway. 

3. Transition provision: 

Transitioning from one standard to another is allowed during the transitional period. Nevertheless, when a supplier has transitioned to the 2024 standard for some product, all the new SDSs and labels must comply with the 2024 standard. The list of products and their versions need to be known by employers for the updating of their libraries. 

Manufacturers and Importers: Creating and Transmitting the SDS 

It is the duty of chemical manufacturers and importers to prepare an SDS. Chemical manufacturers must assess each dangerous substance, categorize it based on HCS guidelines, and prepare a 16-section SDS as per OSHA's Appendix D. 

1. Hazard Classification and SDS Creation 

Manufacturers/importers must: 

• Assess all information available about the chemical (toxicological, physical, and environmental) 

• Classify hazards based on HCS criteria (health, physical, environmental) 

• Produce an SDS in 16 sections in English that represents the hazard classification correctly 

• Make sure that the SDS contains all necessary elements from Appendix D 

2. A Note on the Sixteen Sections 

The 16-section format of SDS is based on the GHS system of the United Nations, but OSHA's Appendix D is the official one for the USA. Differences: 

• GHS offers an international standard; the OSHA Appendix D provides enforcement requirements for the USA. 

• Sections 12–15 (environmental information, disposal considerations, transportation information, and regulatory information) are not enforced by OSHA since they are out of its jurisdiction, but they must be included in the SDS anyway. 

3. Key Manufacturer and Importer Obligations 

• Classification of Hazards: Classify all hazards according to HCS guidelines 

• SDS preparation: Prepare an 16-section SDS in English according to Appendix D 

• Labeling containers: Label, tag, or mark each container leaving the workplace with required information (product identifier, signal word, pictogram, hazard statement, precautionary statement, supplier identifier) 

• First shipment of SDS: Deliver the SDS with the first shipment of a hazardous chemical 

• Revision of SDS: Deliver the revised SDS with the first shipment following any revisions 

• Three-month requirement for revisions: Revisions must be made to the SDS within three months after acquiring new significant hazard information 

• Provision of SDS on request: Deliver an SDS to any downstream customer (distributor or employer) requesting an SDS 

4. Where Importers Differ 

However, importers share the same duties as manufacturers along with one extra responsibility: the ability to correlate SDSs from abroad with OSHA standards. Foreign manufacturers could deliver SDSs that conform to local legislation (EU REACH/CLP, Canada WHMIS, for example) but not to OSHA Appendix D. Importers should: 

• Review foreign SDSs for compliance with HCS 2024 

• Update hazard classifications, labeling, and SDS content as needed 

• Ensure Section 1 includes a U.S. address and contact information 

• Translate the SDS into English (supplemental translations are permitted but not required)  

Distributors: Transmitting Down the Chain 

Distributors generally transmit rather than author SDSs. Their core duty is to ensure the most current SDS from the manufacturer or importer accompanies every downstream shipment.  

Distributor Obligations by Customer Type 

Important Clarifications 

• The retail exemption is not a blanket retail exemption. It applies only to consumer products used in the workplace in the same manner and duration as typical household use. For example, a retail store selling bleach to a school for custodial use must provide an SDS if the use differs from typical household use (e.g., large-scale or frequent use).  

• Repackaging/relabeling can move a distributor into manufacturer-level responsibilities. If a distributor repackages or relabels a chemical in a way that changes its hazards (e.g., diluting, blending, or transferring it to a different container type), they assume manufacturer-level duties, including hazard classification and SDS creation.  

Employers: Obtaining, Maintaining, and Providing Access 

Employers are the consumers of SDSs and hold very crucial roles in ensuring hazard communication at the workplace. While they rarely prepare SDSs (except when they are manufacturing, importing, or repackaging chemicals), they have to ensure that SDSs are available and used appropriately. 

Core Employer Obligations 

• Get the SDS: Get an SDS for every hazardous chemical in your facility from the supplier (manufacturer, importer, or distributor) 

• Keep copies: Keep an up-to-date copy of an SDS for each hazardous chemical; keep old SDSs if you need to keep exposure information 

• Ensure availability: Make sure that SDSs are always accessible to workers at all work shifts in their workplaces 

• Give access to employees/OSHA: The workers should have immediate access to SDSs; OSHA should be allowed access to SDSs during inspections 

• Develop and maintain a written HazCom program: Create, implement, and maintain a written hazard communication program explaining the management of SDSs 

• Train workers: Train workers on the use of SDSs, on hazard classification, pictograms, and signal words, and on precautionary statements 

What "Readily Accessible" Actually Requires 

Misinterpretation of the "readily accessible" rule under OSHA is common. According to the rule: 

• Direct access without any intermediary: Employees should have the ability to obtain the SDS without having to ask for permission from the supervisor, safety manager, or IT personnel. 

• Access should be available on all shifts. 

• Within the work area: Employees must be able to access SDSs from their work area without leaving the area (e.g., via a computer terminal, printed binder, or mobile device). 

Electronic Access—and the Condition Most Guidance Omits 

Electronic SDS systems are permitted and widely used, but OSHA imposes specific conditions: 

• Employees must be trained to use the system. Training must cover how to log in, search, and retrieve SDSs.  

• Access must be available from the work area. Employees must not need to leave their work area to access an SDS. 

• Access must work during every shift. The system must be operational during all shifts, including nights and weekends. 

• There has to be an appropriate back-up plan for such instances/outages. In case of any problem with the electronic system (i.e., network outage or power outage), the employer should have an alternative plan through which immediate access to the SDS is possible. 

• Immediate access to the SDS cannot be dependent on someone else obtaining it. The employee should be able to obtain the SDS independently. 

Language and Literacy 

OSHA mandates that SDSs be provided in English, but it is okay for the employer to give additional translations for employees who lack English proficiency. Training needs to be provided in a language and terminology that the employees can comprehend. In cases where the employees have difficulty with reading, the employer should make use of illustrations and demonstrations.

Employers Who Also Manufacture, Import, or Repackage 

Some employers have dual responsibilities: they use chemicals in their operations and also manufacture, import, or repackage chemicals for distribution. In these cases, they must fulfill both manufacturer/importer and employer obligations.  

1. Examples of Dual-Responsibility Employers 

• Blending/formulating: A facility that blends chemicals for internal use and also ships blended products to customers must classify hazards, author SDSs, and transmit them to customers—while also maintaining SDSs for all raw materials used on-site.  

• Importing directly: An employer that imports chemicals directly from foreign suppliers must reconcile foreign SDSs with OSHA requirements, author compliant SDSs, and transmit them downstream—while also maintaining SDSs for all other chemicals used on-site.  

• Repackaging/relabeling: An employer that repackages or relabels chemicals (e.g., transferring from bulk drums to smaller containers for sale) assumes manufacturer-level duties if the repackaging changes hazards.  

• Laboratories shipping hazardous chemicals: Laboratories that ship hazardous chemicals to other facilities must author SDSs and transmit them, even if they also use those substances internally.  

2. Critical Distinction 

Using a chemical ≠ manufacturing it. Simply using a chemical in a process (e.g., cleaning, production, maintenance) does not trigger manufacturer-level duties. However, changing, repackaging, or importing a chemical can trigger manufacturer-level responsibilities. Employers must carefully evaluate their operations to determine whether they have dual responsibilities.  

Who Is Exempt, and Where the Rules Are Modified 

Not all chemicals in the workplace require SDSs. OSHA provides specific exemptions and modified application rules for certain categories. 

Fully or Partially Exempt Categories 

• Articles: Solid items that do not release hazardous chemicals under normal use (e.g., steel beams, plastic parts) are exempt. 

• Consumer products: Products used in the workplace in the same manner and duration as typical household use are exempt.  

• But if the use of the chemical deviates (for example, large or more frequent use), then an SDS is required. 

• Food, Drugs, Cosmetics: Any item regulated by the FDA (for example, food-related products, drugs in their solid finished form, and cosmetics) is exempted from HCS requirements. 

• Hazardous wastes: These are regulated by the Resource Conservation and Recovery Act (RCRA) and hence are exempted under HCS but are governed by others. 

• Drugs in solid finished form: Finished forms of drugs such as pills, tablets, and capsules are exempted from HCS. 

Modified application 

• Labs: Labs have different requirements under the Lab standard (29 CFR 1910.1450). 

• Sealed containers: Employers do not need to label or provide SDSs for hazardous chemicals in sealed containers that remain unopened during normal use (e.g., unopened drums in storage). However, SDSs must be available if the container is open. 

Critical point: The consumer-product exemption depends on manner and duration of use, not simply where the product was purchased. For example, a retail store selling bleach to a school for custodial use must provide an SDS if the use differs from typical household use.  

What If a Supplier Won't Provide an SDS? 

SDSs are required by law from the suppliers, but there could be delays or refusals. It is the responsibility of the employers to prove the good faith efforts taken to get the SDS and decide on continued usage or otherwise. The following are the steps involved: 

• Send a formal request in writing: Send a formal written request either in the form of an email or a letter mentioning the name of the product, its manufacturer, and the date of the request. 
• If there is no response: Follow-up after 5-7 business days in the form of a phone call or another written request if you have not received any response. Document everything. 
• Move higher up in the chain: If the distributor does not reply, then contact the manufacturer or importer. 
• Maintain documents: Keep records of all your requests and follow-up efforts and responses, if any. This will serve as evidence of your good faith efforts if there is an OSHA inspection. 
• Decide on continued usage: If even now the supplier has refused to give you the SDS, then decide on continued usage or otherwise.

How Long Must You Keep a Safety Data Sheet? 

A common misconception is that OSHA requires SDSs to be retained for 30 years. In reality, HCS does not establish a simple 30-year SDS retention requirement. The "30-year rule" comes from OSHA's Access to Employee Exposure and Medical Records standard, 29 CFR 1910.1020. 

Current SDS Requirement Under HCS 

Employers must maintain a current SDS for each hazardous chemical in the workplace. If a chemical is no longer used, the SDS does not need to be retained under HCS alone.  

Where the "30-Year Rule" Comes From 

29 CFR 1910.1020 requires employers to retain employee exposure records for 30 years. If an SDS is used as an exposure record (e.g., to document employee exposure to a hazardous chemical), it must be retained for 30 years. However, employers can comply with this requirement in two ways: 

Retention Options 

Warning: If choosing the alternative record option, employers must capture where and when the chemical was used before discarding the SDS. Without this information, the alternative record is insufficient for compliance.  

SDS Update and Maintenance Responsibilities 

The SDS is a living document that needs to be updated whenever new hazard information comes into view. There are different responsibilities assigned by the chain of supply on the updating and maintenance of SDSs. 

Stakeholder Responsibilities for SDS Updates 

Critical Point: Employers Must “Pull” Updated SDSs 

The supplier does not always ensure that an updated SDS gets passed on to customers that do not reorder their product. In the case of products that do not get reordered by any customer, it becomes the responsibility of the employer to obtain an updated SDS from the supplier/manufacturer of the product. This becomes even more important for HCS 2024, which requires SDSs that conform to the new standard by November 20, 2026. 

Training Requirements 

SDS access alone is not enough. Employees must be trained to find, read, and use SDS information effectively. Training is a core employer obligation under HCS. 

What Effective SDS Training Covers 

• Accessing SDSs: Methods of accessing SDSs electronically or in printed form; methods of using the backup retrieval system when there is a problem with electronic access 

• Using the backup retrieval system: Actions to take in case the electronic system is not working 

• Understanding SDSs sections: Understanding the 16-section format of SDSs; finding information in each section (hazards in Section 2, PPE in Section 8, first aid in Section 4) 

• Hazard classifications: Health, physical, and environmental hazards; classification of hazards according to HCS 2024 

• Pictograms/signals: Identification of GHS pictograms (flame, skull and crossbones, etc.) and signals (Danger, Warning, etc.) 

• Precautionary statements: Understanding and using tc.) 

• PPE: Personal Protective Equipment that is required when dealing with chemicals 

• First aid/emergency information: Location of information about first aid, spill response, emergency contacts, etc. 

• Revised SDSs: Identifying the SDS that has been updated 

Connection to HCS 2024 Reclassification Requirements 

The HCS 2024 standard includes new hazard categories and classifications. As such, employers need to train employees on new requirements, particularly where there have been reclassifications. For instance, a chemical that was previously categorized as "flammable liquid Category 2" may now fall into the category of "flammable liquid Category 1."

Training Requirements

SDS access alone is not enough. Employees must be trained to find, read, and use SDS information effectively. Training is a core employer obligation under HCS.

What Effective SDS Training Covers

• Accessing SDSs: Methods of accessing SDSs electronically or in printed form; methods of using the backup retrieval system when there is a problem with electronic access
• Using the backup retrieval system: Actions to take in case the electronic system is not working
• Understanding SDSs sections: Understanding the 16-section format of SDSs; finding information in each section (hazards in Section 2, PPE in Section 8, first aid in Section 4)
• Hazard classifications: Health, physical, and environmental hazards; classification of hazards according to HCS 2024
• Pictograms/signals: Identification of GHS pictograms (flame, skull and crossbones, etc.) and signals (Danger, Warning, etc.)
• Precautionary statements: Understanding and using tc.)
• PPE: Personal Protective Equipment that is required when dealing with chemicals
• First aid/emergency information: Location of information about first aid, spill response, emergency contacts, etc.
• Revised SDSs: Identifying the SDS that has been updated

Connection to HCS 2024 Reclassification Requirements

The HCS 2024 standard includes new hazard categories and classifications. As such, employers need to train employees on new requirements, particularly where there have been reclassifications. For instance, a chemical that was previously categorized as “flammable liquid Category 2” may now fall into the category of “flammable liquid Category 1.”

State Plan States 

OSHA-approved state plans operate in 22 states and jurisdictions. These state plans must be at least as effective as federal OSHA but may impose additional requirements. The following points are for every multistate organization: 

• State requirements must be at least as effective as federal requirements. State plans cannot be less stringent than federal OSHA. 

• Some states may impose additional requirements. For example, California's Proposition 65 or New Jersey's Worker and Community Right to Know Act may impose additional SDS or labeling requirements.  

• Multistate organizations should verify state-specific obligations. Employers operating in multiple states should verify state-specific requirements for each location, especially for SDS retention, training, and labeling. 

Building a Defensible SDS Program 

An effective SDS program is not only compliant but also guarantees the accuracy, availability, and usability of hazard information. Here are six suggestions: 

• Designate ownership. Establish who owns the SDS program (EHS manager or compliance specialist) 

• Match SDSs with the chemical inventory. Compare SDSs with the inventory of chemicals to find any discrepancies 

• Perform regular audits. Perform quarterly or biannual audits to make sure SDSs are accurate, available, and compliant with HCS 2024 

• Check SDS for availability. Make sure the employees can always have access to the SDS by checking electronic and backup systems periodically 

• Document of SDS requests. Document all requests for SDS and make notes regarding the date of request, contact person, and response 

• Document training completion. Document training of the employees on the use of SDSs and hazards associated with HCS 2024 

Centralized SDS Management Platforms 

Centralized SDSmanagementt systems such as CloudSDS, SDS Manager, and SafetyChain may be used to: 

• Provide revision control by automatically detecting out-of-date SDSs and prompting users on changes 

• Access control by recording users that have accessed specific SDSs and when 

• Notify users about revised SDS from suppliers or approaching deadlines of HCS 

A Note on Non-US Jurisdictions 

The following document discusses the U.S. OSHA HazCom standard requirements. However, other jurisdictions have other requirements: 

• EU REACH/CLP: Needs SDSs for substances and mixtures which meet certain criteria; SDS format according to EU Regulation 453/2010 (conformant with GHS but with certain EU-specific requirements) 

• Canada WHMIS: Needs SDSs in both English and French; SDS format according to WHMIS 2015 (conformant with GHS Revision 7 but with Canadian-specific requirements) 

• Others: There are other regimes in countries like Australia, Japan, and China that have different SDS requirements and GHS-conformant regulations 

Those who need to comply with regulations from more than one jurisdiction need to verify the applicable requirements. 

Conclusion 

Responsibility for Safety Data Sheets flows through a clear chain: manufacturers and importers classify hazards and author SDSs; distributors transmit SDSs downstream; and employers obtain, maintain, provide access, and train employees. Employers that only use chemicals do not create SDSs, but those that manufacture, import, or repackage chemicals assume dual responsibilities. The major practical takeaway: Employers cannot simply wait for suppliers to send revised SDSs, especially products they no longer reorder. Under HCS 2024, employers must proactively verify SDS compliance and ensure all SDSs meet the updated standard by the November 20, 2026 deadline for substances. 

Frequently Asked Questions 

1. Does an employer have to create safety data sheets? 

No, employers that only use chemicals are not required to create SDSs. Their duty is to obtain SDSs from suppliers, maintain them, and provide access to employees. However, employers that manufacture, import, or repackage chemicals must create SDSs and transmit them downstream. 

2. Can safety data sheets be kept electronically instead of on paper? 

Yes, electronic SDS systems are permitted. However, employers must ensure employees are trained to use the system, access is available from the work area during every shift, and an adequate backup exists for outages or emergencies. 

3. How long do I have to keep a safety data sheet? 

OSHA's HCS does not require SDSs to be retained for 30 years. However, if an SDS is used as an employee exposure record under 29 CFR 1910.1020, it must be retained for 30 years. Employers can comply by retaining the SDS itself or by keeping an alternative record (chemical identity, location, and dates of use) for 30 years. 

4. What are the HCS 2024 compliance deadlines? 

• Manufacturers, importers, distributors: 

• May 19, 2026, for substances 

• November 19, 2027 for mixtures 

• Employers: 

• November 20, 2026 for substances 

• May 19, 2028 for mixtures 

5. What should I do if a supplier will not send an SDS? 

Request the SDS in writing, follow up, escalate through the supply chain (contact the manufacturer if the distributor does not respond), keep documentation of all communications, and evaluate whether continued use of the chemical is appropriate without hazard information. 

7. Do distributors have to provide an SDS with every shipment? 

Yes, distributors must provide the most current SDS with every shipment of a hazardous chemical to downstream customers (employers or other distributors). They must also provide an SDS upon request. 

8. Are consumer products in the workplace exempt from SDS requirements? 

Consumer products are exempt only if they are used in the workplace in the same manner and duration as typical household use. If the product is used differently (e.g., large-scale or frequent use), an SDS is required. 

9. Must SDSs be readily accessible on every shift? 

Yes, SDSs must be readily accessible to employees in their work areas during every work shift, including nights, weekends, and overtime. Electronic systems must have adequate backups for outages or emergencies. 

References 

• OSHA. 29 CFR 1910.1200 – Hazard Communication. https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1200 osha 

• OSHA. Hazard Communication Standard; Final Rule. Federal Register, May 20, 2024. https://www.osha.gov/laws-regs/federalregister/2024-05-20 osha 

• OSHA HCS Amendments Primarily Align with GHS Rev 7. May 30, 2024. https://www..com/osha-hcs-amendments-primarily-align-with-ghs-rev-7/  

• Get Ready for OSHA's GHS Revision 7 Updates. April 22, 2025. https://www..com/resources/ghs-revision-7-updates  

• 3Eco. U.S. OSHA Amends HazCom To Align With GHS Revision 7. September 26, 2024. https://www.3eco.com/article/expert-analysis-u-s-osha-amends-hazcom-to-align-with-ghs-revision-7/ 3eco 

• HSI. How GHS Rev. 7 Improves Hazard Communication. June 29, 2026. https://hsi.com/blog/ghs-rev-7-workplace-safety hsi 

• . OSHA Extends Hazard Communication Standard Compliance Dates. January 24, 2026. https://www..com/osha-extends-hazard-communication-standard-compliance-dates/  

• SDS Manager. Workplace Safety Roles: Who Is Responsible for Providing SDS? July 24, 2025. https://.com/us/sds-management-articles/who-is-responsible-for-providing-sds/  

• Science Insights. Who Requires SDS Sheets Under OSHA and Beyond. March 17, 2026. https://scienceinsights.org/who-requires-sds-sheets-under-osha-and-beyond/ scienceinsights 

• Technology. OSHA GHS Hazard Communication Update Final Rule 2024. May 21, 2024. https://www..com/-news/may-2024/osha-hazcom-standard-updated-with-ghs-revision-7  

• GHS Pictograms. OSHA HCS 2024 Changes: Hazard Communication Final Rule. May 8, 2026. https://ghspictograms.com/compliance/osha-hcs/osha-hcs-2024-changes/ ghspictograms 

• Total SDS. OSHA Adopts GHS Revision 7. September 24, 2024. https://www.totalsds.com/osha-to-adopt-ghs-revision-7/ totalsds 

• SDS HQ. OSHA SDS Requirements — The Practical 2026 Checklist. July 21, 2026. https://www..com/guides/osha-sds-requirements-checklist  

• SBN Software. How Does OSHA's Hazard Communication Standard Affect SDS Requirements? December 4, 2024. https://sbnsoftware.com/blog/how-does-oshas-hazard-communication-standard-affect-sds-requirements/ sbnsoftware 

• KHA. Safety Data Sheets: Who's Responsible for Providing Them? August 11, 2025. https://www.kha.com/safety-data-sheets-whos-responsible-for-providing-them/ kha