Introduction 

Dealing with Safety Data Sheets (SDS) is the single most important task in occupational safety and regulatory compliance. But many organizations have the issue of expired or incomplete SDS documents—a situation that poses grave safety risks as well as subjects businesses to enormous legal liability. It is imperative to learn how to effectively deal with such a situation to ensure OSHA compliance and the safety of your workforce. 

 

The Real Cost of Lost and Obsolete SDS Sheets 

When Safety Data Sheets go missing or become obsolete, the implications reach far beyond mere administrative burden. Obsolete SDS sheets can have wrong hazard information, possibly causing employees to misuse chemicals or use the wrong protective gear. In emergency situations, first responders can be provided with wrong information regarding the chemical makeup or emergency response procedures. 

From a regulatory standpoint, OSHA fines for lost or expired SDS can be very serious with fines potentially over $12,000 per violation. In addition to monetary fines, there are human losses. Workers operating on outdated safety information are at higher risk for accidents, chemical burns, respiratory hazards, or long-term health impairment. Further, organizations can be sued by injured workers or their families if injuries can be linked to absent or erroneous safety documents. 

 

Why SDS Sheets Become Outdated or Missing 

Several factors contribute to SDS management challenges in the workplace. When chemical manufacturers update their products—whether due to reformulation, new hazard data, or regulatory changes—they must revise the corresponding SDS. However, manufacturers are not required to automatically send updated sheets to all previous customers; this responsibility falls on employers. 

Organizations tend to have SDS gaps during switching suppliers, adding new chemicals without standard procedure documentation, or not keeping a systematic review process. In other facilities or labs, especially smaller ones, SDSs may never have been procured initially, and therefore compliance gaps can go on for years. 

 

Comprehending Regulatory Obligations for SDS Revision 

OSHA’s Hazard Communication Standard (HCS) mandates manufacturers and importers to revise SDS within three months of determining new and relevant information regarding chemical hazards or after changes in regulatory obligations. Triggers may include new hazard classifications, alterations in chemical composition, revisions to occupational exposure limits, or revisions to GHS (Globally Harmonized System) classifications. 

For employers, the regulatory situation is a bit different. OSHA does not require periodic review of SDS at stated intervals such as every three years or yearly, but best practices suggest reviewing SDS at least every three to five years to make sure they are up to date and accurate.

This is especially necessary when the formulation of the product changes; regulations change or new scientific information becomes available regarding chemical hazards. 

Key to this is the employer’s duty—rather than the manufacturer’s—to ensure that SDSs being utilized are the latest versions available. This involves actively keeping abreast of updates and asking for new sheets from suppliers as necessary. 

 

What to Do When an SDS is Missing 

When you realize that an SDS is not available in your workplace, swift action is necessary. The initial step is to check that the sheet is indeed missing and not just misplaced or kept in an unusual place. Verify your digital databases, physical files, and any archived documents before deciding that the sheet is actually missing. 

After you’ve verified the missingness, inform your supervisor and assign someone to find the document. OSHA requires employers to make a good faith effort, documented, to find missing SDS, especially in inspections. What that does not mean is that you can just shrug it off and forget about it—you have to take concrete actions to find the sheet. 

 

1. Reaching Out to Manufacturers Directly

The most reliable source for an SDS is the chemical manufacturer themselves. Start by contacting the manufacturer’s customer service department or visiting their website—most companies now maintain online SDS libraries that can be searched by product name or CAS number. When requesting an SDS, provide as much detail as possible about the product, including the specific name, grade, CAS number, and your supplier if different from the manufacturer. 

Keep all attempts at communication—phone calls, emails, letters, and dates—documented. These documents provide proof of good faith effort and safeguard you in OSHA inspections. If the company that manufactured the product is out of business, look up what became of the company; assets and product lines are often purchased by other manufacturing companies that can offer revised SDS. 

 

2. Accessing Online Databases

There are several online databases that offer searchable lists of SDS from many different manufacturers. These can prove to be very useful when direct contact with the manufacturer is unsuccessful or when working with older chemicals. Be certain you are using reliable sources that offer manufacturer-specific sheets, not generic or generic approximations. 

 

3. Interim Safety Measures

As you’re taking action to obtain a missing SDS, institute temporary protective actions. This may involve limiting access to the chemical to trained staff only, demanding greater personal protective equipment (PPE) until the sheet is acquired, or interrupting temporary use of the chemical if hazards can’t be evaluated. Make sure all employees are aware that the SDS is missing and discuss any available hazard information from alternative credible sources. 

 

How to Respond to Outdated SDS Sheets 

When you determine an SDS is out of date, immediately substitute it with the new one. Ask your supplier or manufacturer for updated sheets, citing that you require the latest revision since your present sheet was last updated on a particular date. Most manufacturers supply updated SDS for free and welcome organizations to take compliance seriously. 

When updating an expired SDS, define a clear process for your employees. Take the old sheet out of employee access areas to avoid confusion but keep it in your archives based on retention specifications. Revise your chemical inventory list to indicate the new sheet version and inform all employees working with the chemicals of any new hazard data or safety procedures. 

 

1. Performing SDS Audits

Recurring SDS audits are at the root of avoiding stale sheet issues. Perform a thorough audit with a minimum of every six to twelve months, preferably prompted by distinct events such as new deliveries, supplier changes, or when facilities are put on notice of new regulatory mandates. When auditing, confirm that each SDS revision date is up to date, cross-check sheets against your current chemical inventory, and check if any sheets need update due to known regulatory or hazard information changes. 

 

2. Retention and Archival Requirements

It has been mistakenly believed that OSHA mandates organizations to retain SDS for 30 years. This is not true. OSHA’s HazCom standard does not specify any minimum retention for SDS documents themselves. Nevertheless, OSHA’s Access to Employee Exposure and Medical Records standard (29 CFR 1910.1020) calls for retention of employee exposure records for 30 years. 

What that looks like in reality is that you can throw away old SDS once they are superseded, as long as you keep a chemical inventory list and record of what hazardous materials were used, where, and when. But if the makeup of a chemical altered between versions of old and new SDS, then keep the old sheet too, because it notes a different formulation. 

 

Best Practices for SDS Management 

To avoid constant SDS issues, have a written hazard communication program that is tailored to address SDS management in detail such as acquisition procedures, update procedures, storage areas, and employee access procedures. Appoint specific individuals to be in charge of monitoring SDS status, ordering updates, and performing regular audits. 

Adopt a centralized SDS management system—either physical or electronic—giving all employees immediate access to up-to-date sheets. In case an electronic system is used, have backup plans in place for power outages or system crashes. Use SDS management software that tracks updates automatically and notifies you when sheets need to be reviewed. 

Train all staff on accessing SDS, reading the 16-section format, and identifying when hazard information has been changed. When new or revised SDS are implemented, training sessions emphasizing changes and implications to workplace procedures are held.  

 

Conclusion 

Managing missing or obsolete SDS sheets necessitates a proactive, system-based method rooted in OSHA regulation requirements and safety principles within the workplace. By instituting documented processes for procuring sheets, regular auditing, having proper archival processes, and having strong SDS management systems in place, organizations can guard workers, promote regulatory adherence, and provide evidence of due diligence upon inspection. The return on investment for detailed SDS management comes in safety, compliance, and organizational reputation.