Safety Data Sheets (SDS) serve as critical communication tools in hazardous chemical management, providing essential information about chemical hazards, safe handling practices, and emergency response measures. However, responsibility for providing and maintaining these documents extends across the entire supply chain, from chemical manufacturers to employers. Understanding who bears these responsibilities and how to comply with regulatory requirements is essential for organizations seeking to maintain a safe and legally compliant workplace.  

 

The Responsibility Chain in SDS Management 

Safety Data Sheets are not the responsibility of a single entity but rather a shared obligation among multiple parties within the supply chain. Each stakeholder plays a distinct role in ensuring that accurate, current, and accessible hazard information reaches workers who handle hazardous chemicals. The distribution of responsibilities follows a defined sequence, beginning with chemical manufacturers and ending with employers who must ensure accessibility to their workforce. 

The legal framework governing these responsibilities stems primarily from OSHA’s Hazard Communication Standard (HCS), which requires manufacturers, importers, distributors, and employers to work together to communicate chemical hazards effectively. Understanding the specific obligations of each party is fundamental to achieving compliance and protecting employee safety.  

 

Manufacturers: Creating and Distributing SDS 

Chemical manufacturers bear the primary responsibility for creating Safety Data Sheets for their products. This responsibility begins with hazard classification, where manufacturers must determine and classify all potential hazards associated with their chemical products. Manufacturers must assess physical hazards such as flammability and reactivity, as well as health hazards including toxicity and sensitization potential.  

Once hazard classification is completed, manufacturers must prepare comprehensive Safety Data Sheets that meet the 16-section format established by the Globally Harmonized System (GHS). These sections must include accurate, scientifically supported information about the chemical properties, hazards, and safe handling procedures.  

 

Key Manufacturer Responsibilities 

Manufacturers must fulfill several critical obligations:  

• Determine and classify chemical hazards accurately based on scientific evidence 

• Create SDS documents using the standardized 16-section GHS format 

• Ensure all labels on containers include required hazard information, pictograms, signal words, and precautionary statements 

• Provide SDS to distributors and employers at the time of first shipment or before 

• Update SDS within three months of becoming aware of significant new hazard information 

• Ensure that SDS information remains accurate and reflects current scientific understanding 

Manufacturers must also provide SDS to distributors or employers at the time of first shipment of hazardous chemicals. OSHA does not require manufacturers to provide SDS with every shipment; however, when an SDS is updated with significant new information, manufacturers must provide the revised version with the next shipment after the update occurs.  

 

Importers: Ensuring Compliance for International Products 

Chemical importers shoulder responsibilities similar to manufacturers when they bring hazardous substances into the country. Importers must ensure that chemicals meet domestic hazard communication requirements before distribution, which often involves updating or revising SDS provided by foreign manufacturers to comply with U.S. regulations.  

Importers serve as critical links in the supply chain, particularly when foreign-manufactured chemicals do not initially comply with OSHA’s Hazard Communication Standard or the GHS format requirements. By taking on these responsibilities, importers help maintain consistency and accuracy of hazard information throughout the U.S. market. 

Importers must provide SDS to distributors and employers following the same timeline requirements as manufacturers. They are equally responsible for ensuring that SDS information reflects accurate hazard data and is updated within three months of discovering significant new information about hazards.  

 

Distributors: Maintaining Chain of Custody 

Distributors play a crucial intermediary role by ensuring that accurate SDS accompanies products as they move through the supply chain. Distributors must maintain SDS received from manufacturers or importers and pass this information to downstream users, which may include employers, retailers, or other distributors.  

 

Distributor Obligations Across Different Customer Types 

The specific requirements for distributors vary depending on the type of customer receiving the chemical product. Understanding these distinctions is important for compliance:  

Customer Type	Distributor Responsibility	Timing Requirement
Commercial Accounts	Provide SDS with initial shipment and first shipment after update	At time of delivery or before
Retail Customers (with commercial account)	Provide SDS upon request and post sign indicating availability	Upon request
Retail Customers (without commercial account)	Provide manufacturer/importer contact information upon request	Upon request
General Retail Sales	No SDS required if distributor doesn’t maintain commercial accounts	Not applicable

 

Distributors who do not maintain commercial accounts or use products in their own workplaces are not required to provide SDS to retail distributors. However, if a distributor repackages or relabels chemicals, they must ensure that accurate labeling and SDS information accompany the repackaged product.  

 

Employers: The Final Link in Accessibility 

Employers represent the final critical link in ensuring that workers have access to accurate, current Safety Data Sheets. While manufacturers and distributors create and transmit SDS, employers must take active steps to maintain these documents in their workplace and ensure that employees can access them readily.  

 

Core Employer Responsibilities 

Employer obligations regarding SDS management include several key requirements:  

• Obtain SDS for all hazardous chemicals used or stored in the workplace 

• Maintain current copies of SDS in easily accessible locations 

• Update SDS whenever revised versions are received from suppliers 

• Ensure employees know where SDS are located 

• Provide training on how to read and interpret SDS 

• Create systems to promptly communicate updates to affected employees 

• Establish protocols for regular review and updating of SDS records 

Employers cannot simply rely on having SDS available; these documents must be truly accessible without creating barriers to employee access. OSHA emphasizes that employees should not need to ask supervisors or managers to view SDS, as this could create a psychological barrier that discourages workers from seeking necessary safety information.  

 

Accessibility Requirements: Making SDS Available to Employees 

OSHA’s Hazard Communication Standard specifies that employers must maintain SDS in the workplace and ensure they are “readily accessible” to employees during each work shift when workers are in their work area. This requirement has several important implications for workplace safety management.  

 

What “Readily Accessible” Means in Practice 

Readily accessible means that employees must be able to quickly obtain SDS information without significant barriers or delays. The standard specifies that physical location is less important than ensuring no obstacles to prevent employee access. Electronic access is permitted as long as employees have immediate access without encountering barriers such as login requirements that create delays or dependencies on supervisors.  

Employers should consider establishing SDS management systems that include both formats:  

• Physical copies: Organized in binders or filing systems located in work areas where employees use chemicals 

• Digital systems: Computers or mobile applications accessible to all employees with training on how to use these systems 

• Hybrid approaches: Combining physical and digital options to accommodate different employee preferences and needs 

The location of SDS should be clearly marked and communicated to all employees. Employers must ensure that language barriers or literacy levels do not prevent workers from understanding SDS information. Providing translations or supplemental training for non-English-speaking employees may be necessary to ensure true accessibility.  

 

SDS Update and Maintenance Requirements 

Maintaining current SDS requires ongoing attention and systematic processes. Chemical manufacturers must update SDS within three months of becoming aware of significant new information about hazards. However, employers have the primary responsibility for ensuring that the SDS in their workplace reflects the most current information available.  

 

Timeline for SDS Updates 

The regulatory framework for SDS updates establishes clear timelines and responsibilities:  

Party	Trigger Event	Update Timeline	Communication Requirement
Manufacturer /Importer	Discover significant new hazard information	Within 3 months	Provide to distributors with next shipment
Distributor	Receive updated SDS from manufacturer	Upon receipt	Pass to downstream users
Employer	Receive updated SDS from supplier	Upon receipt	Compare to previous version and communicate changes to affected employees
Employer	Discover new hazard information independently	Within appropriate timeframe	Update SDS and train employees

 

Importantly, manufacturers are not required to automatically send updated SDS to all past customers. Employers have responsibility for actively seeking updated versions and ensuring their binders or digital systems contain current information. Regularly comparing revision dates on received SDS to those already maintained helps identify when updates are needed.   

 

Training Requirements for SDS Access and Use 

Providing SDS access represents only part of the employer’s obligation; employees must understand how to use these documents effectively. OSHA requires employers to provide training to all employees who may be exposed to hazardous chemicals, including how to read and interpret SDS.  

 

Effective SDS Training Components 

Comprehensive training on Safety Data Sheets should address several key elements:  

• How to locate and access SDS in the workplace 

• The purpose and structure of the 16 standardized SDS sections 

• How to identify hazard classifications, pictograms, and signal words 

• Understanding precautionary statements and recommended safety measures 

• How to recognize changes between old and new SDS versions 

• Emergency procedures and first-aid measures relevant to specific chemicals 

• Personal protective equipment requirements for chemicals handled 

Training should use actual SDS for chemicals employees work with rather than generic examples. This approach ensures that workers become familiar with the specific format and hazards they will encounter in their daily tasks. Training must be provided before employees handle chemicals and whenever new hazards or chemicals are introduced to the workplace.  

 

Best Practices for SDS Management 

Organizations that successfully manage SDS compliance implement systematic processes and establish clear responsibility assignments. Several best practices help ensure that SDS programs remain effective and compliant. 

Establishing a centralized SDS management system helps prevent gaps in coverage and ensures consistency across the organization. Designating specific personnel responsible for obtaining, updating, and distributing SDS clarifies accountability and reduces the likelihood of outdated information remaining in use.  

Regular audits of SDS collections, at minimum annually, help identify missing documents or outdated versions. Organizations should conduct room-by-room inventories to identify all hazardous chemicals in use and verify that corresponding SDS are available and current.  

Modern SDS management software platforms enable organizations to maintain both physical and digital copies, streamline update processes, and track employee training. These solutions can automatically alert users when revised SDS are received and facilitate communication of changes to relevant employees.  

 

Regulatory Frameworks and Compliance 

Different regulatory jurisdictions may impose varying requirements for SDS management. While OSHA’s Hazard Communication Standard provides the primary framework in the United States, international standards including the European Union’s REACH Regulation and Canada’s WHMIS establish additional requirements in their respective regions.  

Organizations operating in multiple jurisdictions must ensure compliance with local regulations governing SDS requirements, update timelines, and employee training. Consulting with EHS professional’s familiar with applicable regulations helps ensure that SDS management systems meet all legal requirements. 

 

Conclusion 

Providing and maintaining Safety Data Sheets in the workplace requires coordinated effort across multiple parties, from chemical manufacturers through employers. Manufacturers and importers bear responsibility for creating accurate, current SDS and communicating them through the supply chain. Distributors ensure that this information reaches employers along with chemical shipments. Ultimately, employers must take active steps to obtain, maintain, update, and make accessible SDS for all hazardous chemicals in their workplace, while ensuring that employees receive training on how to use these critical documents.  

By understanding the specific responsibilities of each party and implementing systematic SDS management processes, organizations can fulfill their legal obligations while creating safer workplaces where employees have the information and knowledge necessary to handle hazardous chemicals safely. The investment in comprehensive SDS management directly translates to reduced accidents, decreased regulatory violations, and most importantly, enhanced protection for worker health and safety.