Safety Data Sheets (SDS) serve as critical documents that communicate chemical hazards, protective measures, and emergency response procedures to employees and downstream users. However, maintaining SDS compliance remains one of the most challenging areas of workplace safety management. Recent REACH enforcement initiatives found that approximately 35% of inspected SDSs fail to meet compliance standards, while OSHA continues to cite hazard communication violations as one of the top workplace safety issues, with 527 citations issued in fiscal year 2024.  

Understanding and correcting common SDS mistakes can significantly reduce compliance risks, prevent costly penalties, and most importantly, protect employee safety. 

 

8 Common mistakes and Their Solutions 

Mistake 1: Using Outdated SDS Versions 

The Problem 

Relying on outdated or incorrect SDS versions represents one of the most prevalent compliance failures in workplace environments. Chemical formulations change regularly; regulations evolve, and suppliers update documents accordingly. Organizations that fail to implement systematic version control risk exposing employees to incorrect hazard information.  

Impact of This Mistake 

When employees follow outdated procedures, they may unknowingly handle chemicals using incorrect protective measures, potentially leading to exposure of incidents. Additionally, auditors may discover conflicting procedures across your facility, resulting in regulatory fines and reputational damage.  

How to Fix It 

Establish an automated update tracking system through digital SDS management platforms. These systems notify your team when suppliers release new versions, allowing you to: 

• Deploy new SDS documents to all access points simultaneously 

• Archive previous versions with clear documentation 

• Schedule mandatory employee retraining on revised hazard information 

• Audit compliance with version control requirements 

 

Mistake 2: Incomplete or Incorrect Chemical Classification 

The Problem 

Among REACH enforcement inspections, 35% of non-compliant SDSs contained incorrect or incomplete hazardous substance listings in Section 3 (Composition). Misclassification cascades through other critical sections, particularly affecting exposure controls and protective equipment recommendations.  

Cascading Effects of Classification Errors 

Section	Consequence	Impact
Section 3 (Composition)	Incorrect substance identification	Employees use wrong PPE
Section 8 (Exposure Controls)	Inadequate OEL guidance	Insufficient protective measures
Section 9 (Physical Properties)	Missing hazard data	Improper storage and handling
Section 11 (Toxicology)	Contradictory toxicological data	Ineffective emergency response

How to Fix It 

Implement a comprehensive chemical classification audit process: 

• Review all hazard classifications against current GHS guidelines and supplier documentation 

• Verify that Section 3 accurately lists all hazardous substances with correct percentages 

• Ensure each hazard classification in Section 2 corresponds to detailed information in Sections 3, 8, 9, and 11 

• Assign qualified personnel to review classifications quarterly or when supplier information changes 

 

Mistake 3: Inadequate Employee Access to SDS Information 

The Problem 

Simply maintaining SDS files is insufficient if employees cannot access them during emergencies. Time-critical situations demand immediate retrieval of safety information, yet many organizations store SDSs in centralized locations that workers cannot quickly reach.  

How to Fix It 

Implement multiple access channels that ensure availability in any work situation: 

• Digital mobile-friendly platforms with searchable databases 

• Physical SDS binders at each workstation 

• QR code links on chemical containers 

• Multilingual versions for diverse workforces 

• 24/7 online accessibility for off-shift emergencies 

Equally important is conducting regular employee training on SDS location and interpretation, ensuring workers can quickly retrieve and apply safety information.  

 

Mistake 4: Missing or Improper Secondary Container Labeling 

The Problem 

Secondary containers—bottles, drums, or tanks created by decanting chemicals from original packaging—frequently lack proper hazard labels. Employees may lose critical hazard information when chemicals are transferred, leading to confusion and unsafe handling practices.  

How to Fix It 

Establish a standardized secondary container labeling protocol: 

• Label all secondary containers immediately upon creation with the same information as the original 

• Include hazard pictograms, signal words, and hazard statements 

• Add precautionary statements specific to your workplace 

• Use durable, water-resistant labels that remain legible throughout the container’s lifecycle 

• Train all staff responsible for container transfers on labeling requirements 

 

Mistake 5: Poor Chemical Inventory Management 

The Problem 

Organizations that fail to maintain accurate chemical inventory records cannot ensure that SDS documentation matches the chemicals actually in use. This creates gaps in compliance records and hampers accurate EPA reporting, particularly for chemicals subject to special regulations.  

Common Inventory Management Failures 

• Chemicals in use with missing or outdated SDS files 

• Duplicate entries for identical products from different suppliers 

• Missing disposal documentation 

• Inadequate tracking of chemical usage and expiration dates 

• Inaccurate quantities that prevent proper emergency response planning 

How to Fix It 

Implement a structured chemical inventory management system that includes: 

• Regular physical audits matching stored chemicals against database records 

• Monthly reconciliation of SDS files with current inventory 

• Automated alerts when chemicals approach expiration dates 

• Clear disposal procedures with documentation trails 

• Centralized database accessible to all relevant departments 

 

Mistake 6: Neglecting Employee Training and Hazard Communication 

The Problem 

Providing access to SDSs without adequate employee training on interpretation and application represents a critical compliance gap. Simply having documents on file does not satisfy OSHA’s HazCom requirements; employees must understand how to use this information to protect themselves.  

This deficiency frequently appears in OSHA inspection findings, where inspectors discover that while SDSs exist, employees cannot explain what hazards they face or what protective measures apply to their work.  

How to Fix It 

Develop a comprehensive hazard communication training program that includes: 

• Initial training when employees begin working with hazardous chemicals 

• Annual refresher training covering SDS interpretation 

• Hands-on practice locating specific sections (Section 8 for exposure limits, Section 15 for regulatory information) 

• Practical scenarios demonstrating emergency response using SDS information 

• Department-specific training tailored to chemicals employees handle 

• Documentation of all training with attendance records 

 

Mistake 7: Incomplete or Missing Written HazCom Program 

The Problem 

The most frequently cited violation during OSHA inspections is the absence of a written Hazard Communication (HazCom) program. This foundational document outlines how your organization manages all aspects of chemical hazard communication.  

Required Elements of a Written HazCom Program 

• Inventory of all hazardous chemicals in the workplace 

• Methods for informing employees about hazards (labels, SDS access, training) 

• Chemical labeling requirements for primary and secondary containers 

• Procedures for updating chemical information when new hazards are identified 

• Emergency response procedures using SDS information 

• Employee training schedule and documentation methods 

• System for receiving and implementing supplier SDS updates 

How to Fix It 

Draft a comprehensive written HazCom program if one does not exist or update your existing program to address current regulatory requirements and your facility’s specific operations. Ensure the program reflects actual workplace practices and includes clear responsibility assignments. 

 

Mistake 8: Data Quality Issues and Missing Exposure Scenarios 

The Problem 

REACH enforcement inspections identified data quality issues in 27% of reviewed SDSs. Common errors include inaccuracies in hazard identification, composition of details, and exposure control measures. Additionally, 18% of inspected SDSs lacked mandatory exposure scenarios that explain how workers might be exposed to the chemical.  

How to Fix It 

Verify data quality across all SDS sections: 

• Cross-reference hazard statements with documented hazard data 

• Ensure exposure scenarios clearly describe work activities that could result in exposure 

• Confirm that occupational exposure limits (OELs) from Section 8 align with each country or region where chemicals are used 

• Validate physical property descriptions against actual product characteristics 

• Include detailed PPE recommendations specific to exposure scenarios 

 

 

Moving Toward Compliance Excellence 

Effective SDS management requires commitment to systematic processes, regular auditing, and continuous improvement. Organizations that invest in digital SDS management platforms, comprehensive employee training, and structured compliance verification significantly reduce regulatory violations and, more importantly, create safer work environments where employees understand and can respond to chemical hazards. 

The cost of implementing robust SDS compliance programs is minimal compared to potential penalties—which can reach $165,514 per willful violation—and immeasurable compared to preventing workplace injuries and protecting employee health. 

 

Frequently Asked SDS Compliance Questions 

 

1. Do SDS Expire?

No, Safety Data Sheets do not have a fixed expiration date under OSHA regulations. Unlike consumer products such as food or medications, OSHA’s Hazard Communication Standard does not mandate a predetermined validity period for SDSs. However, this does not mean they remain valid indefinitely.  

The key principle is that SDSs must be updated whenever new, significant hazard information becomes available. The revision date on an SDS is critical for determining if you are using the most current version. If an SDS has not been updated in several years, it is advisable to contact the supplier to verify whether the document reflects the latest scientific and regulatory information.  

Some manufacturers may add expiration dates to their SDSs as part of internal policies, but these are not mandated by OSHA regulations. The focus should remain on ensuring that the information within the SDS is accurate and relevant rather than relying solely on printed expiration dates.  

 

2. Does OSHA Allow Digital-Only SDS?

Yes, OSHA fully accepts and encourages the use of electronic SDS databases. Organizations can maintain SDSs in a digital format as their primary storage method, provided specific conditions are met:  

Key Requirements for Digital SDS Compliance: 

• Accessibility: Electronic SDS must be readily accessible to all employees during each work shift when they are in their work areas. Employees must be able to access them immediately without barriers.  

• Hazard Communication Plan: The organization’s written Hazard Communication Plan must explicitly document how electronic SDSs are maintained and made available to employees.  

• Hard Copy Availability: While paper binders are no longer required, employers must ensure employees can obtain hard copies of SDSs if requested.  

• Backup Systems: A backup electronic or physical system must be available in case of power outages or other emergencies.  

• Employee Training: If SDSs are stored electronically, employees must possess the necessary computer skills to access the documents quickly and independently.  

OSHA has acknowledged that electronic SDS databases are more accessible and functional than traditional paper binders, making digital storage a preferred compliance approach when properly implemented.  

 

3. Who is Responsible for SDS Updates?

SDS update responsibilities are distributed across multiple parties in the supply chain:  

• Manufacturers and Importers: These entities bear primary responsibility for creating SDSs and updating them whenever new hazard information becomes available. OSHA requires manufacturers and importers to update SDSs within three months of discovering new or significant hazard information. This includes changes to chemical classifications, protective measures, or product formulations.  

• Distributors: Distributors must ensure that updated SDSs are provided to employers with the next shipment after the manufacturer issues updates. However, manufacturers are not required to automatically send updated SDSs to customers; distributors and employers are responsible for requesting and obtaining current versions.  

• Employers: The management must establish a system for obtaining, maintaining, and distributing current SDSs. This includes reviewing SDSs for accuracy whenever the chemical composition changes; new hazard information emerges, or regulatory standards are updated. Employers are legally obligated to ensure that all staff members exposed to hazardous chemicals are aware of updates and understand the implications of the new safety information.  

 

4. How Often Should Training Occur?

Hazard Communication (HazCom) training does not have a mandatory annual frequency requirement under OSHA standards. Instead, training must be conducted at specific trigger points:  

Initial and Required Training Frequency: 

• New Hire Training: All employees must receive HazCom training before or at the time they are assigned to work with hazardous chemicals.  

• New Chemical Introduction: Additional training is required whenever new physical or health hazards are introduced to the work area, provided employees have not previously received training on those specific hazards.  

• Changes in Worker Responsibilities: Retraining is necessary when an employee’s job duties change, and they are newly exposed to hazardous chemicals.  

• No Mandatory Annual Refresher: Unlike some OSHA standards (such as bloodborne pathogens, respiratory protection, and fire extinguisher training, which require annual training), HazCom does not mandate annual refresher training. However, OSHA recommends that employers periodically review their Hazard Communication programs and provide refresher training when circumstances warrant it.  

• Best Practice Recommendation: While not legally required, many EHS professionals recommend annual or periodic HazCom refresher training to ensure employees retain knowledge about label elements, the standardized 16-section SDS format, and proper chemical handling procedures.