Hazard communication safety data sheets: the complete guide for employers

Last updated 2026-07-09

What is a safety data sheet, and what was it called before?

A safety data sheet (SDS) is a standardized document that tells you exactly what a hazardous chemical is, what it can do to people and property, and how to handle it safely. Every SDS follows the same 16-section format, set by OSHA's Hazard Communication Standard at 29 CFR 1910.1200. That sameness is the whole point. A worker who moves from one job site to another finds the flash point, the first-aid steps, or the spill procedure in the same place every time. ^[1]

The old name was Material Safety Data Sheet, or MSDS. Most people used that term from the 1980s through 2012. OSHA rewrote the Hazard Communication Standard in 2012 to line up with the United Nations Globally Harmonized System of Classification and Labelling of Chemicals (GHS). That update fixed the format and changed the official term to SDS. The required sections and the 16-section structure both come from that 2012 revision. ^[1]

So if someone asks "what is the name of the hazard communication data sheets" or just says "MSDS," they mean the same thing. The answer is safety data sheet (SDS). MSDS is the pre-2012 name, nothing more. You'll still see MSDS in old training decks, dusty binders, and casual talk, but OSHA's current standard uses SDS exclusively.

You can learn more about the broader hazard communication program that ties SDS, labels, and employee training together.

Which OSHA standard requires safety data sheets?

The governing rule is 29 CFR 1910.1200, the Hazard Communication Standard (HazCom), sometimes called HCS 2012 after its big revision. OSHA published the final rule on March 26, 2012, in the Federal Register (77 FR 17574), with full compliance for most employers required by June 1, 2016. ^[1]

The standard applies to any employer whose workers may be exposed to hazardous chemicals. That covers general industry under 29 CFR 1910.1200, construction under 29 CFR 1926.59, maritime under 29 CFR 1915.99, and agriculture under 29 CFR 1928.21. The core job is the same across every sector: get SDS from chemical manufacturers or importers, keep them accessible, and train workers to use them. ^[1]

The rule puts the work of writing SDS on chemical manufacturers and importers. Employers who use hazardous chemicals but don't make or import them are downstream users. Their job is to obtain the SDS, keep them current, and make sure every worker can read and use them. ^[1]

States with OSHA-approved State Plans must adopt rules at least as protective as the federal standard. About half of all states run their own plans. If you're in one of those states, check whether it has layered extra requirements on top of the federal baseline. OSHA's State Plans page is the fastest way to find out. ^[1]

What are the 16 sections of an SDS, and what does each one cover?

OSHA's Appendix D to 29 CFR 1910.1200 spells out the exact content required in each section. Here's what each one holds: ^[1]

Section	Name	What it tells you
1	Identification	Product name, manufacturer contact, recommended uses
2	Hazard(s) identification	GHS hazard classification, signal word, pictograms, hazard and precautionary statements
3	Composition/ingredients	Chemical identities, CAS numbers, concentrations
4	First-aid measures	Symptoms of exposure, immediate treatment by route (skin, eye, inhalation, ingestion)
5	Fire-fighting measures	Suitable extinguishing agents, hazardous combustion products, PPE for firefighters
6	Accidental release measures	Spill containment, cleanup procedures, protective equipment
7	Handling and storage	Safe handling practices, incompatible materials, storage conditions
8	Exposure controls/personal protection	OSHA PELs, ACGIH TLVs, recommended PPE, engineering controls
9	Physical and chemical properties	Flash point, boiling point, vapor pressure, appearance, odor
10	Stability and reactivity	Conditions to avoid, incompatibilities, hazardous decomposition products
11	Toxicological information	Routes of exposure, LD50/LC50 data, carcinogenicity, reproductive hazards
12	Ecological information	Environmental fate, aquatic toxicity (non-mandatory under OSHA)
13	Disposal considerations	Safe disposal methods (non-mandatory under OSHA)
14	Transport information	DOT, IATA, IMDG classification (non-mandatory under OSHA)
15	Regulatory information	Other regulations beyond OSHA (non-mandatory under OSHA)
16	Other information	Revision date, key changes since last version

Sections 1 through 11 are mandatory. Sections 12 through 15 must appear on the SDS, but OSHA doesn't enforce their content under HazCom; other agencies like EPA and DOT do. Section 16 is mandatory and must show the date of the most recent revision. ^[1]

Section 8 earns its keep day to day. It's where you find the OSHA Permissible Exposure Limit (PEL), the legal ceiling. It also lists the ACGIH Threshold Limit Value (TLV), which is often stricter and more current than the PEL, because OSHA's PELs for many chemicals haven't changed since 1971. When Section 8 shows a TLV tighter than the PEL, most safety professionals follow the TLV as a best practice, even though only the PEL is legally enforceable.

Section 2 is the first place a worker should look in an emergency. The GHS signal word (Danger or Warning), the pictograms, and the hazard statements give a fast read on severity. "Danger" flags a more severe hazard category. "Warning" flags a less severe one.

How do safety data sheets relate to GHS labels and pictograms?

The SDS and the container label are a matched pair. The label is the quick reference on the container itself. The SDS is the full technical document behind it. Both run on the same GHS classification system, so the pictograms and hazard statements on the label should match Section 2 of the SDS. ^[1]

GHS defines nine pictograms. The ones workers see most are the flame (flammable), the skull and crossbones (acute toxicity), the health hazard symbols (an exclamation mark for irritants, a torso silhouette for severe health effects), and the corrosion symbol. Each pictogram maps to specific hazard categories in OSHA's Appendix C to 29 CFR 1910.1200. ^[1]

Every label must carry the product identifier, signal word, hazard statements, precautionary statements, pictograms, and supplier contact information. OSHA requires the label in English, though you can add other languages. ^[1]

For small containers, OSHA allows abbreviated labels, but the full SDS still has to be accessible. When workers move a chemical from its original container into a secondary container, that secondary container also needs a label, unless the worker will use up the contents within the same work shift. ^[1]

For a chemical-specific walkthrough, the hcl safety data sheet article shows what each section looks like for hydrochloric acid. It's a good way to see how a real document reads.

Where do employers get safety data sheets, and how do they stay current?

Chemical manufacturers and importers must, under 29 CFR 1910.1200(g), send an SDS with each initial shipment of a hazardous chemical and with the first shipment after an SDS is updated. ^[1] As a downstream employer, you should get SDS automatically. In practice, distributors let this slip, so build a process that confirms you have a current SDS before a new chemical ever hits your floor.

For chemicals already in your building, most manufacturers post current SDS on their websites. You can search by product name or CAS number. Many distributors run searchable SDS portals too. When a manufacturer's site comes up empty, the OSHA HazCom page points to guidance on tracking one down. ^[2]

SDS have no fixed expiration date under OSHA. Manufacturers must update them when new hazard information surfaces or the formulation changes. Section 16 of every SDS shows the revision date. If your copy is more than five years old, check the manufacturer's website for a newer version.

One thing OSHA is blunt about: employers cannot make workers show a union card or pay any fee to see an SDS. ^[1] Access has to be immediate and free.

Your written hazard communication program, a separate requirement under 29 CFR 1910.1200(e), has to spell out how workers will reach SDS on every shift, including night crews and off-site jobs. Inspectors check this specifically. If you're building that program from scratch, the SafetyFolio program generator can produce a compliant HazCom program in about 15 minutes, SDS access procedures included. ^[2]

How must employers make SDS accessible to workers?

29 CFR 1910.1200(g)(8) requires SDS to be readily accessible to employees during each work shift when they're in their work area. ^[1] "Readily accessible" means immediately, with no barriers in the way. A worker shouldn't have to call a supervisor, wait for a computer to boot, or dig through a binder locked in an office.

Three approaches cover most workplaces: a physical binder at each station where chemicals are used, a shared network drive or intranet page, or third-party SDS management software. All three pass muster. What OSHA checks is whether the system actually works for the people using it, including workers with limited English or low literacy.

For mobile crews and field operations like construction, OSHA has accepted written procedures where workers call a central location and get SDS information by phone right away. An OSHA letter of interpretation from 2003 confirms that electronic access systems are fine as long as a backup covers power outages or system failures. ^[3]

OSHA doesn't dictate the format. Paper binders work. Tablets work. A wall-mounted kiosk works. What matters is that a worker can pull the SDS for any chemical they touch, right now, from their work area.

Some employers file SDS by location instead of alphabetically by product. That often makes more sense in a facility where different areas use different chemical families. Either way, workers need to know where to look, and they need to be trained on the system.

What are the OSHA training requirements for safety data sheets?

Training isn't optional. Under 29 CFR 1910.1200(h), employers must train workers on the hazardous chemicals in their work area at initial assignment and again whenever a new hazard shows up. ^[1] Training has to cover how to read and use SDS, more than the fact that SDS exist.

Training must include the location and availability of the written HazCom program, the location of SDS for chemicals in the work area, how to read labels and SDS, and the steps workers can take to protect themselves: PPE, work practices, and emergency procedures. ^[1]

OSHA sets no minimum number of training hours. It requires that training be effective. An inspector can pull an employee aside and ask them to show where the SDS live and how to read one. If workers can't do it, the training record on file counts for nothing.

For workers with limited English, training has to be delivered in a language and vocabulary they understand. OSHA has cited employers for giving English-only training to Spanish-speaking crews.

Building out a wider training program? The osha training article maps the full set of OSHA-required training topics across industries. For a formal credential, osha 30 training folds HazCom into its 30-hour curriculum.

What does OSHA require in a written hazard communication program that covers SDS?

The written hazard communication program is a separate but connected requirement. 29 CFR 1910.1200(e) requires every employer with hazardous chemicals in the workplace to keep a written program. ^[1] It has to describe how the company handles labels, SDS, and employee training.

For SDS specifically, the written program must explain how the employer will obtain an SDS for each hazardous chemical, how they'll keep them current, and how workers will reach them. ^[1] The program doesn't have to be long. It has to be specific enough that a new safety manager could read it and know exactly what to do.

One common mistake is a generic program that never names the actual chemicals in the building. OSHA expects the chemical inventory to be part of the program or attached to it. That list ties your SDS collection to the written procedure.

Small employers with simple chemical profiles often run a two- or three-page written program. That's fine. What OSHA cites is the program that doesn't exist at all, or the one that exists on paper while nobody knows where it is.

The written program is also where you document how you handle chemicals brought in by contractors. If a contractor carries a chemical onto your site, you're on the hook for having its SDS available to your own workers. ^[1]

How does OSHA enforce SDS requirements, and what do citations look like?

Hazard communication is one of OSHA's most-cited standards, year after year. In fiscal year 2023, HazCom (29 CFR 1910.1200) was the second most frequently cited OSHA standard, with 2,696 violations. ^[4] The usual citations involve missing or inaccessible SDS, weak training, and written programs that are incomplete or copied off a template with no ties to the actual workplace.

Inspectors check SDS compliance in a plain way. They ask workers where the SDS are, ask them to find the SDS for a specific chemical in their area, and check whether the SDS collection matches the chemical inventory. A chemical in use with no SDS behind it is a citation.

Penalties for willful or repeat violations can reach $161,323 per violation as of 2024; serious violations top out at $16,131 per instance. ^[5] OSHA adjusts both figures every year for inflation. A facility running 30 chemicals with no SDS can stack up multiple per-instance citations fast.

OSHA reads the written program during inspections too. A program that says "SDS are available in the front office" for a company with 80 workers across three production areas is going to draw questions. Inspectors know a compliant program from a paper-only one.

If you get a citation, you can contest it within 15 working days. Most small employers find it cheaper to fix the violation and negotiate the penalty than to fight it, though that depends on the citation. For related paperwork, the incident report article covers the OSHA recordkeeping rules that tend to surface in the same inspection.

What hazardous chemicals commonly need SDS in small businesses?

Almost every small business keeps chemicals that trigger SDS rules, even when the owner never thinks of the place as a chemical environment. The test is whether a chemical is "hazardous" under the GHS classification OSHA uses. That covers physical hazards (flammability, reactivity) and health hazards (toxicity, carcinogenicity, irritation). ^[1]

Common culprits in small workplaces: cleaning products with bleach or quaternary ammonium compounds, spray lubricants and penetrating oils, welding fumes and shielding gases, paints, stains, coatings, forklift battery acid, and compressed gases. Even plain isopropyl alcohol in a first aid kit is a flammable liquid at high enough concentration and needs an SDS. ^[1]

The exclusions are narrow. OSHA exempts hazardous waste regulated solely under RCRA, tobacco products, wood and wood products in their natural state (coated or treated wood is not exempt), articles (items that don't release a hazardous chemical during normal use), food and drugs meant for personal consumption at work, and consumer products used the way a consumer would use them. ^[1] That last one matters. A cleaning product used the same way and in the same amount a homeowner would use it is generally exempt. The same product used in bulk all day by a professional cleaner is not.

Forklifts pull in several obligations at once: battery maintenance, fueling, and propane handling all generate SDS. The forklift certification and lockout tagout programs both cross paths with chemical hazards in those settings.

How do safety data sheets connect to a complete written safety program?

SDS are one piece of a larger written hazard communication program, which is itself one piece of your overall written safety program. OSHA's HazCom standard requires the written program under 29 CFR 1910.1200(e), but the SDS collection and the training records are what make that program real on the floor. ^[1]

A full written safety program for most small employers also covers lockout/tagout (29 CFR 1910.147), PPE hazard assessments (29 CFR 1910.132), emergency action plans (29 CFR 1910.38), and a handful of other standards depending on the industry. SDS feed several of these. Section 8 drives your PPE selection. Section 6 drives your emergency spill response. Section 7 drives your storage and handling procedures.

The efficient path is to start with a chemical inventory, pull the SDS, then use Sections 7 and 8 of each one to build your handling and PPE procedures. The SDS already did the technical work. Your written program just translates it into steps that fit your workplace.

If you want a faster route, SafetyFolio's safety program generator builds a full written HazCom program that names your specific chemicals and work areas in about 15 minutes. It won't replace a real audit of your chemical inventory, but it hands you a compliant framework to build on. The written program is one of the first things an inspector asks for, often inside the first ten minutes of a visit.

What changed when OSHA updated HazCom to the GHS format in 2012?

The 2012 revision was the biggest change to HazCom since the standard first issued in 1983. OSHA adopted the GHS classification and labeling system. That move standardized the 16-section SDS format, retired the old free-form MSDS, and brought in the standardized pictograms and signal words. ^[1]

Before GHS, an MSDS could take almost any shape. Some ran two pages, some ran twenty. There was no required section order and no required content structure. Different manufacturers arranged the same information different ways, which cost workers real time when they needed the flash point or the first aid steps in a hurry.

The GHS format ends that guesswork. Section 9 is always physical and chemical properties. Section 4 is always first aid. A trained worker in a crisis knows where to look without reading the whole thing. That's the practical payoff.

OSHA's 2012 final rule set phased deadlines. Manufacturers and importers had to comply by June 1, 2015. Distributors had until December 1, 2015. Employers had until June 1, 2016, to update their written programs, swap MSDS binders for GHS-format SDS, and retrain workers. ^[1]

OSHA estimated the 2012 revision would prevent roughly 500 chemical-related injuries and illnesses per year and save 43 lives annually, with net benefits near $475 million per year once fully in place. ^[6] Those numbers come from OSHA's regulatory impact analysis published with the 2012 final rule.

There was a trade benefit too. Lining up with GHS meant U.S. exporters no longer needed separate hazard documentation for international shipments, since most trading partners run the same GHS system.

Frequently asked questions

What is the difference between an SDS and an MSDS?

They're the same document under different names. MSDS (Material Safety Data Sheet) was the term OSHA used before its 2012 HazCom revision. SDS (Safety Data Sheet) is the current term under 29 CFR 1910.1200, and it follows a standardized 16-section GHS format. If you still have old MSDS binders, they should have been replaced with GHS-format SDS by June 1, 2016, when full employer compliance was required.

How many sections are in an OSHA safety data sheet?

There are 16. Sections 1 through 11 and Section 16 are mandatory under OSHA's HazCom standard (29 CFR 1910.1200, Appendix D). Sections 12 through 15 must appear on the SDS, but OSHA doesn't enforce their content; EPA, DOT, and other agencies govern those. All 16 sections must be present and in order.

Are employers required to keep SDS for every chemical in the workplace?

Yes, for every hazardous chemical. 29 CFR 1910.1200(g) requires an SDS for each hazardous chemical used or stored. Consumer products used in the same manner and quantities a consumer would use them are generally exempt, but that exception is narrow. Most cleaning products, lubricants, paints, solvents, and compressed gases used in a business setting require SDS.

Can employers keep SDS electronically instead of in a paper binder?

Yes. OSHA accepts electronic SDS systems as long as there's no barrier to immediate access during a shift. A 2003 OSHA letter of interpretation confirmed electronic access is fine if a reliable backup exists for power or system failures. Workers must be trained on the system, and it has to be reachable from their work area, more than from a supervisor's office.

How often do SDS need to be updated?

OSHA requires manufacturers and importers to update an SDS whenever new hazard information appears or the formulation changes. There's no fixed schedule in the standard. For employers, the practical rule is to check for updates periodically, especially on high-hazard chemicals, and replace your copy when the manufacturer issues a new version. Section 16 of every SDS shows the revision date.

What happens if a chemical arrives without an SDS?

Under 29 CFR 1910.1200(g)(6), employers must contact the manufacturer, importer, or distributor to get a missing SDS. The manufacturer is required to provide it. Keep a record of your request. If the SDS still doesn't arrive, report the problem to OSHA. You can also pull a copy from the manufacturer's website or an SDS database in the meantime, but the manufacturer's own current version is the authoritative one.

Do contractors working on my site need to share SDS with me?

Yes. 29 CFR 1910.1200(e)(2) requires employers to make sure SDS are available for hazardous chemicals that contractors bring onto the site, so your own employees can access them. Your written HazCom program should include a process for exchanging this information with contractors before work starts. The contractor provides the SDS; you're responsible for making it accessible to your workers.

What is a trade secret, and can it affect what's in an SDS?

Manufacturers can withhold the specific identity of a trade secret ingredient under 29 CFR 1910.1200(i), but they must still disclose the hazard information, health effects, and protective measures. If a worker or healthcare provider needs the identity for a medical emergency, the manufacturer must provide it immediately. For non-emergencies, the standard sets out a process for getting trade secret information under a confidentiality agreement.

How long must employers keep SDS on file?

For current chemicals, there's no limit; you keep the SDS as long as the chemical is in your facility. For discontinued chemicals, the HazCom standard itself sets no retention period, but OSHA's access to exposure records rule (29 CFR 1910.1020) requires records relating to chemical exposures be kept for 30 years. Many safety professionals treat SDS from removed chemicals as exposure records and keep them accordingly.

Does OSHA's HazCom standard apply to farms and agricultural employers?

Yes, under 29 CFR 1928.21, HazCom applies to agricultural operations with workers who may be exposed to hazardous chemicals. That includes pesticides, fertilizers, fuels, and other chemical products. Pesticides registered under FIFRA and labeled to EPA requirements are exempt from OSHA's labeling requirements, but SDS still must be available for them.

What section of an SDS tells me what PPE workers need?

Section 8, Exposure Controls and Personal Protection. It lists recommended gloves, respiratory protection, eye and face protection, and skin protection, plus engineering controls like ventilation. It also carries the OSHA PEL and ACGIH TLV for the chemical. Section 8 should feed directly into your PPE hazard assessment under 29 CFR 1910.132.

Is there a required format for the written hazard communication program?

OSHA doesn't mandate a template, but 29 CFR 1910.1200(e)(1) specifies what the program must address: labels, SDS, and employee training, plus how workers will access SDS and a chemical inventory. The program has to fit your workplace; a generic form that never names your actual chemicals and work areas doesn't satisfy the standard. OSHA offers a sample plan, but you have to customize it to your facility.

Can workers refuse to work with a chemical if there's no SDS?

Workers have the right to refuse work they reasonably believe poses imminent danger, and missing SDS for a hazardous chemical could support that belief. OSHA's HazCom standard also gives workers the right to access hazard information. This doesn't automatically authorize a work stoppage, but an employer with no SDS for a chemical workers are told to use is in a weak position if a worker refuses the task.

What is the GHS, and why does it matter for SDS?

The Globally Harmonized System of Classification and Labelling of Chemicals (GHS) is a United Nations framework that standardizes how chemical hazards are classified and communicated worldwide. OSHA aligned HazCom with GHS in 2012. That alignment is why SDS now follow a fixed 16-section format, use standardized pictograms, and carry signal words like Danger or Warning. An SDS from a European maker follows the same structure as one from a U.S. maker.

Sources

1. OSHA, 29 CFR 1910.1200 Hazard Communication Standard (full regulatory text including appendices): 16-section SDS format, mandatory sections, employer obligations to obtain and provide access to SDS, training requirements, written program requirements, trade secret provisions, and GHS alignment from 2012 revision
2. OSHA, Hazard Communication topic page (SDS guidance and resources): OSHA guidance on obtaining and maintaining SDS and links to related resources
3. OSHA, Letter of Interpretation: Electronic Access to Material Safety Data Sheets (MSDS), March 20, 2003: Electronic SDS systems are acceptable if a backup system exists for power or computer failures
4. OSHA, Top 10 Most Cited Standards, Fiscal Year 2023: Hazard Communication (29 CFR 1910.1200) was the second most-cited OSHA standard in FY2023 with 2,696 violations
5. OSHA, Penalties page (current civil penalty amounts): Willful or repeat violations up to $161,323 per violation; serious violations up to $16,131 per instance as of 2024
6. OSHA, Final Rule: Hazard Communication, 77 FR 17574 (March 26, 2012), Regulatory Impact Analysis: OSHA estimated the 2012 GHS alignment would prevent approximately 500 injuries/illnesses per year, save 43 lives annually, and generate net benefits of approximately $475 million per year
7. United Nations Economic Commission for Europe, Globally Harmonized System of Classification and Labelling of Chemicals (GHS): GHS framework defining standardized chemical classification, labeling, and safety data sheet format internationally
8. OSHA, Hazard Communication topic page (Small Entity Compliance Guide and written program guidance): Employer obligations for written HazCom program content including SDS access procedures and chemical inventory requirements
9. OSHA, 29 CFR 1910.1020, Access to Employee Exposure and Medical Records: Records relating to employee chemical exposures must be retained for 30 years
10. OSHA, Hazard Communication topic page (GHS labels and pictograms guidance): GHS label requirements including nine pictograms, signal words, hazard and precautionary statements, and supplier identification