Safety Data Sheets (SDS) are more than just compliance documents. They play a critical role in helping employees and anyone handling chemical products understand potential hazards, respond correctly during emergencies, and use substances safely. Having accurate and up-to-date SDS is essential—not only to meet OSHA’s Hazard Communication (HazCom) standard, but also to protect people, workplaces, and operations. This raises an important question: who is responsible for providing and maintaining these documents for your organization? 

From chemical manufacturers to distributors and employers, multiple parties play a role in the SDS lifecycle. Regulations such as OSHA’s Hazard Communication Standard clearly define these responsibilities, but they are often misunderstood or overlooked. As chemicals move through the supply chain, the obligation to provide accurate, up-to-date SDS does not disappear. Rather, it shifts and expands. 

Understanding who is responsible for SDS management is not just about avoiding penalties. It is about protecting employees, ensuring quick access to safety information, and staying prepared during inspections or emergencies. So, if you’re an employer or someone who works with chemical products every day, now is the time to clear up any confusion. This article will help you. So, continue reading. 

Why is Managing SDSs Important? 

Managing Safety Data Sheets (SDSs) is important. Each of these documents contain essential information about the chemicals used in your workplace. SDSs explain the hazards of a product, how to handle it safely, what protective equipment is needed, and what to do in case of spills, exposure, or emergencies. When SDSs are well managed, employees can quickly find the information they need to stay safe. 

Proper SDS management also helps organizations stay compliant with regulations like OSHA’s Hazard Communication Standard. Inspectors may ask for SDSs at any time. Besides, missing or outdated documents can lead to penalties, delays, or failed audits. Keeping SDSs updated and easily accessible shows that your organization takes safety and compliance seriously. 

Most importantly, effective SDS management protects people. In an emergency, there is no time to search through paper binders or outdated files. Having accurate, up-to-date SDSs available ensures faster response, fewer accidents, and a safer work environment for everyone who works with or around chemical products. 

Who can Provide SDSs? 

1. Manufacturers

  • Create an SDS for every hazardous chemical they produce. 
  • Update the SDS whenever new hazard, health, or regulatory information becomes available. 
  • Ensure that the SDS is accurate, complete, and clearly written. 
  • Provide the SDS to distributors and all downstream users. 

2. Importers

  • Obtain SDSs from foreign suppliers for all imported chemical products. 
  • Prepare a new SDS if one is missing or does not meet local requirements. 
  • Review and verify that the SDS complies with OSHA and GHS standards. 
  • Ensure the SDS is ready and accurate before distributing the product further. 

 

3. Distributors

  • Provide the SDS to the next downstream purchaser with the first shipment or upon request. 
  • Ensure that the most recent and updated version of the SDS is shared. 
  • Pass along revised or updated SDSs as soon as they are received from the manufacturer or importer. 

 

Who must Maintain SDS? 

Maintaining Safety Data Sheets (SDSs) is just as important as providing them. Proper maintenance ensures that safety information is always up-to-date, easily accessible, and matches the chemicals being used in the workplace. Different roles in an organization have specific responsibilities when it comes to SDS maintenance. 

1. Employers

  • Maintain an SDS for every hazardous chemical present in the workplace. 
  • Ensure that SDSs are readily accessible to workers at all times, including during emergencies. 
  • Keep SDSs organized in a consistent system, whether digital or paper-based. 
  • Verify that SDSs match the actual products being used onsite. 
  • Remove SDSs for chemicals that are no longer in use or have been delisted. 

2. EHS Managers & Safety Officers

  • Collect, update, and review SDSs regularly to ensure accuracy. 
  • Conduct periodic audits to verify that SDSs are complete, current, and accessible. 
  • Train employees on how to locate and use SDSs correctly. 
  • Act as the point of contact for questions related to chemical safety information. 

3. Employees 

  • Employees do not have a legal responsibility to maintain SDSs. 
  • They are responsible for accessing SDSs when needed to handle chemicals safely. 
  • Must notify supervisors or safety officers if an SDS is missing, outdated, or unclear. 

Legal Framework for SDS Responsibility 

The responsibility for providing and maintaining Safety Data Sheets (SDSs) is guided by several legal frameworks worldwide. These regulations ensure that chemical hazards are communicated clearly across the supply chain and in the workplace. Understanding these rules helps organizations stay compliant and protects employees by handling chemicals. 

 

1. OSHA HazCom (U.S.) 

In the United States, the Hazard Communication Standard, governed by 29 CFR 1910.1200, sets clear rules for chemical safety. Suppliers and employers must provide an SDS at the time of shipment for any hazardous chemical. Additionally, SDSs must be accessible to employees during every work shift, ensuring workers can quickly access safety information whenever needed. Compliance with OSHA HazCom is essential to maintain a safe workplace and avoid regulatory penalties. 

2. GHS (Globally Harmonized System

The Globally Harmonized System (GHS) provides guidance on the roles and responsibilities of every party in the chemical supply chain, from manufacturers to end users. It requires consistent hazard classification and standardized SDS formatting, making it easier to understand and compare safety information globally. By following GHS guidelines, organizations can reduce confusion, especially when chemicals are imported or exported across borders. 

4. EU CLP & REACH Regulation

In the European Union, chemical safety is regulated under CLP (Classification, Labelling, and Packaging) and REACH (Registration, Evaluation, Authorization, and Restriction of Chemicals). Manufacturers and importers are required to prepare SDSs that comply with EU standards. They also have an obligation to notify downstream users whenever an SDS is updated, ensuring that organizations handling chemicals always have the latest safety information. 

5. WHMIS (Canada)

Canada’s Workplace Hazardous Materials Information System (WHMIS) defines responsibilities for both suppliers and employers. Suppliers must provide accurate SDSs and proper labeling, while employers must ensure SDSs are accessible to employees and that workers are trained to use them correctly. WHMIS rules are designed to communicate chemical hazards clearly, helping prevent accidents and ensuring safe handling in Canadian workplaces. 

 

When must SDS Be Updated? 

Safety Data Sheets (SDSs) must be kept current to ensure chemical hazards are accurately communicated. Updates are required whenever new information about a chemical becomes available, changes occur in its formulation, or regulations evolve. Timely updates protect workers, maintain compliance, and reduce risks in the workplace. 

 

  • Within Three Months of Becoming Aware of New Hazard Information

If a manufacturer or importer learns of new hazards associated with a chemical, the SDS must be updated within three months. This could include newly discovered health risks, flammability concerns, or environmental effects. Quick updates ensure that all users downstream, from distributors to employees, are aware of the latest safety information and can take proper precautions. 

  • When Product Formulation Changes

Any change in the chemical composition of a product requires an SDS update. Adding, removing, or altering ingredients can change the chemical’s hazards or how it should be handled safely. Updating the SDS ensures that users know exactly what is in the product and can follow the correct safety procedures. 

  • When New Toxicology or Regulatory Data Emerges

Scientific research and regulatory updates can reveal new information about a chemical’s health effects, exposure limits, or environmental impact. When new toxicology or regulatory data becomes available, the SDS must be revised. This keeps safety information accurate and compliant with local and international standards. 

  • When New GHS Classifications are Adopted

The Globally Harmonized System (GHS) sets rules for classifying chemical hazards. When new GHS classifications are adopted, the SDS must reflect these changes. This ensures consistent hazard communication worldwide, so users understand risks regardless of where the chemical comes from or is used. 

  • Who is Responsible for SDS Updates 

The manufacturer or importer of the chemical is typically responsible for updating the SDS. They are closest to the source of the product and its hazard information, making them best suited to ensure accuracy. Once updated, the SDS must be distributed promptly to all downstream users, including distributors, employers, and workers, so that everyone handling the chemical has the latest information. 

How must Employers Keep SDS Accessible? 

Employers are required to ensure that Safety Data Sheets (SDSs) are easy to access for all employees who work with or around hazardous chemicals. Accessibility is not just about having SDSs on file—it means workers must be able to find and use them quickly, especially during emergencies. OSHA and other global regulations clearly define how SDSs should be made available. 

1. Acceptable Methods for SDS Access 

Employers can use different methods to provide access to Safety Data Sheets (SDSs), as long as the information is easy to find, up to date, and available to employees at all times. The method chosen should suit the workplace environment and the needs of the workforce. 

  • Paper Binders

Paper SDS binders are an acceptable option if they are clearly labeled, well organized, and kept in locations where employees can easily reach them. The binders must be updated regularly, and old or outdated SDSs should be removed to avoid confusion. 

 

  • Digital SDS Management Systems

Digital systems allow SDSs to be stored in a centralized platform that can be accessed from computers, tablets, or mobile devices. These systems make it easier to keep SDSs current, manage large chemical inventories, and ensure consistent access across multiple sites. 

 

  • QR Code or Mobile App Access

QR codes and mobile apps provide quick, on-the-spot access to SDSs. Employees can scan a code or open an app to view safety information instantly, which is especially useful for field workers, warehouses, and large facilities. 

 

  • Online SDS Portals

Online portals allow employees to search for and view SDSs through a web browser. These portals must be reliable and available during all work shifts, including nights and weekends, to ensure uninterrupted access to safety information.

 

2. Accessibility Requirements 

  • No Lockouts, Passwords, or Delays

Employees must be able to access SDSs instantly. Systems that require passwords, special permissions, or long loading times can slow down response during an emergency and are not considered compliant. 

 

  • No Supervisor Approval Required

Workers should not have to ask a supervisor or manager to access SDSs. SDS information must be available for self-service at all times so employees can quickly review hazards and safety measures when needed. 

 

  • Access at Remote Sites and Emergency Areas  

SDSs must be accessible wherever chemicals are used or stored, including remote job sites, labs, warehouses, production floors, and emergency response areas. This ensures that safety information is available even during spills, exposures, or off-site operations. 

 

What Happens if SDS Responsibilities are Not Met? 

Failure to meet Safety Data Sheet (SDS) responsibilities can lead to serious safety, compliance, and business consequences. These impacts differ across the supply chain but can affect operations, people, and reputation. 

For Manufacturers, Importers, and Distributors 

  • Regulatory Penalties
     

Non-compliant, inaccurate, or missing SDSs can result in fines and enforcement actions from regulatory authorities. Repeated violations may lead to stricter monitoring and legal consequences. 

  • Supply Chain Disruptions
     

Shipments may be delayed, rejected, or stopped if SDSs are missing or do not meet regulatory requirements. This can interrupt business operations and strain relationships with customers and partners. 

 

  • Loss of Compliance Certifications
     

Many safety, quality, and environmental certifications require proper SDS documentation. Failure to maintain compliant SDSs can lead to failed audits, suspension, or loss of certifications. 

 

For Employers 

  • OSHA Fines
      

Employers may face penalties if SDSs are missing, outdated, or not easily accessible to employees, especially during inspections. 

 

  • Non-Compliance during Inspections
     

If workers cannot quickly locate SDSs or are unaware of how to access them, it signals poor hazard communication practices and can result in citations and corrective actions. 

 

  • Workplace Injuries and Legal Liabilities
     

Inaccurate or unavailable SDSs increase the risk of improper chemical handling, which can lead to injuries, illnesses, and legal claims against the organization. 

 

  • Increased Risk during Spills, Exposures, and Fires
     

SDSs provide critical guidance during emergencies, including first aid, spill response, and firefighting measures. Without quick access to this information, emergency response is delayed and the risk of serious harm increases. 

 

Who is Responsible if an SDS is Missing or Incorrect? 

When a Safety Data Sheet (SDS) is missing or contains incorrect information, responsibility depends on where the failure occurs in the supply chain. Understanding these scenarios helps organizations respond quickly, correct the issue, and stay compliant while protecting worker safety. 

 

Missing SDS from the Supplier 

When a chemical is delivered without an SDS, the supplier, which may be the manufacturer, importer, or distributor, is responsible. Regulations require suppliers to provide a compliant SDS at the time of first shipment. Until the SDS is received, the chemical should not be used, as workers do not have the necessary hazard and safety information. 

 

Missing SDS in the Workplace 

If an SDS is available from the supplier but cannot be found in the workplace, the responsibility falls on the employer. Employers must maintain SDSs for all hazardous chemicals on-site and ensure they are accessible to employees at all times. A missing workplace SDS is considered a compliance failure during inspections. 

 

SDS Contains Errors or Inaccurate Information 

When an SDS contains incorrect hazard data, classification errors, or missing sections, the responsibility lies with the manufacturer or importer. They are required to correct the SDS and issue an updated version. Once corrected, the updated SDS must be shared with all downstream users without delay. 

 

Outdated SDS in a Binder or System 

If the SDS exists but is outdated, the employer is responsible for maintaining the latest version. Employers must regularly review and replace old SDSs, whether stored in paper binders or digital systems. Keeping outdated SDSs can be just as risky as having none at all. 

 

Wrong SDS Attached to a Chemical 

If the wrong SDS is linked to a chemical product, the responsibility again lies with the employer. This mismatch can cause serious safety risks, especially during emergencies. Employers must correct the SDS immediately and retrain employees to ensure they understand the correct hazards and handling procedures. 

Common Workplace Mistakes 

Even organizations that handle chemicals regularly can make mistakes when managing Safety Data Sheets (SDSs). These errors often happen due to outdated processes, lack of training, or misunderstandings about compliance requirements. Over time, such mistakes can increase safety risks and lead to regulatory issues. 

 

  • Relying only on Paper Copies that become Outdated

Many workplaces still depend solely on paper SDS binders. While paper copies are allowed, they often become outdated if updates are not replaced promptly. Old or missing pages can result in employees using incorrect safety information, especially during inspections or emergencies. 

 

  • Not Validating SDS against Product Labels

An SDS must match the product label exactly. Failing to cross-check SDS information with labels can lead to incorrect hazard communication. Differences in chemical names, concentrations, or hazard symbols can confuse workers and increase the risk of improper handling. 

 

  • Mixing SDS from Different Manufacturers for Similar Products

Similar chemicals from different manufacturers can have different formulations and hazards. Using one manufacturer’s SDS for another’s product is a common but serious mistake. This can result in incorrect safety instructions and non-compliance during audits. 

 

  • Not Training Employees on SDS Access

Having SDSs available is not enough if employees do not know how to find or use them. Without proper training, workers may hesitate or waste valuable time during an emergency. Regular training ensures employees understand where SDSs are stored and how to read key sections. 

 

  • Confusion between MSDS and SD Formats

Some workplaces still use older Material Safety Data Sheets (MSDS) instead of the standardized SDS format. MSDSs may not follow current GHS requirements and can lack important information. Relying on outdated MSDSs can lead to compliance issues and incomplete hazard communication. 

How to Create a Reliable SDS Management Workflow? 

A reliable SDS management workflow helps organizations stay compliant, reduce safety risks, and ensure employees always have access to accurate chemical safety information. By following a structured approach, employers can avoid common errors and keep SDSs up to date across all locations. 

 

  • Set up a Centralized Digital SDS Library

Create a single, centralized location where all SDSs are stored and managed. A digital SDS library makes it easier to organize documents, control access, and ensure consistency across departments and sites. Employees can quickly search for and retrieve SDSs whenever needed, especially during emergencies. 

 

  • Establish a Quarterly SDS Audit Schedule

Regular audits are essential to ensure SDSs remain updated and accurate. A quarterly audit schedule helps identify missing, outdated, or incorrect SDSs before they become compliance issues. These audits also help confirm that SDSs match the chemicals actually used in the workplace. 

 

  • Assign Clear Roles to Safety Officers

Clearly define who is responsible for SDS-related tasks such as collecting, reviewing, updating, and removing documents. Assigning these duties to safety officers or EHS managers ensures accountability and prevents gaps in SDS maintenance. 

  • Track SD Update Notifications from Suppliers

Manufacturers and suppliers regularly release updated SDSs when new hazard or regulatory information becomes available. Organizations should actively track these updates and replace older versions promptly. This ensures that employees always work with the most recent safety data. 

 

  • Ensure Version History and Backup Storage

Maintaining a version history allows organizations to track changes made to SDSs over time. Backup storage ensures that SDS data is not lost due to system failures or accidental deletion. Together, these practices support audit readiness and long-term compliance. 

Summary Table: Who Is Responsible for What? 

 

Role  Provide SDS  Update SDS  Maintain SDS Access  Use SDS 
Manufacturer  Yes  Yes  No  No 
Importer  Yes  Yes  No   No 
Distributor  Yes  No  No  No 
Employer  No  No  Yes  Yes 
Employer  No  No  No  Yes 

 

Conclusion 

Responsibility for Safety Data Sheets (SDSs) does not rest with a single party. It is shared across the entire chemical supply chain, with each role playing a critical part in ensuring that accurate safety information reaches the workplace. When any link in this chain fails, the risk of non-compliance and workplace incidents increases. 

There is a clear division of responsibility. Manufacturers, importers, and distributors are responsible for providing SDSs and ensuring they are accurate and up to date before chemicals reach the end user. Employers are responsible for maintaining SDSs in the workplace, making sure they are accessible, current, and matched to the chemicals in use. Employees, in turn, are responsible for using SDSs, accessing them when needed, and reporting missing or unclear information. 

When these responsibilities are clearly understood and properly managed, organizations stay compliant with regulations such as OSHA HazCom, GHS, REACH, and WHMIS. More importantly, effective SDS management protects workers, improves emergency response, and creates a safer work environment. Clear ownership, regular reviews, and easy access to SDSs are essential steps toward building a strong and compliant chemical safety program.