What is a material safety data sheet (MSDS) and what replaced it?

Last updated 2026-07-09

What does 'material safety data sheet' actually mean?

A material safety data sheet, almost always shortened to MSDS, was a document that chemical manufacturers and importers had to prepare and ship with any hazardous substance they sold. It told downstream users, meaning your employees and your customers, what was in the product, what physical and health hazards it carried, how to store and handle it, what protective equipment to wear, and what to do when something went wrong.

The operative word is "was." OSHA retired the MSDS in 2012 when it lined up its Hazard Communication Standard with the United Nations Globally Harmonized System of Classification and Labelling of Chemicals (GHS). The replacement is the Safety Data Sheet, or SDS. The old MSDS had no fixed format, so one manufacturer's sheet could look nothing like another's. That inconsistency made training harder and emergency response slower. The SDS fixed it with a mandatory 16-section structure that reads the same every time, for every product, from every supplier.^[1]

You will still hear "MSDS" constantly, especially in older industries and from workers who learned the term decades ago. Under current OSHA rules the correct term is SDS. If someone hands you an MSDS printed before 2016, it covers the same territory as an SDS. It just does it in a less predictable way.

When did OSHA replace the MSDS with the SDS?

OSHA published the revised Hazard Communication Standard (HazCom 2012) in the Federal Register on March 26, 2012.^[1] That revision adopted GHS and introduced the SDS format. Compliance rolled out in phases.

• December 1, 2013: Employers had to train workers on the new label elements and SDS format.
• June 1, 2015: Chemical manufacturers and importers had to be in full compliance with the new labeling and SDS requirements.
• June 1, 2016: Distributors could no longer ship products with old-format labels, and employers had to have updated SDSs for every hazardous chemical in their workplaces.^[1]

That last deadline came and went years ago. If a supplier is still handing you old-style MSDS sheets, that is a compliance problem on their end, and it becomes yours the moment you accept them and rely on them without updating your program. The standard at 29 CFR 1910.1200(g) requires SDSs in the 16-section format.^[2]

General industry follows 29 CFR 1910.1200. Construction is covered under 29 CFR 1926.59, which adopts the same requirements by reference.

What are the 16 sections of a Safety Data Sheet?

This is the core of what the old MSDS tried to do, now in a locked sequence. OSHA's HazCom standard at 29 CFR 1910.1200, Appendix D spells out exactly what goes in each section.^[2]

Section	Title	What it tells you
1	Identification	Product name, manufacturer, intended use, emergency phone number
2	Hazard(s) identification	GHS hazard classification, signal word (Danger/Warning), pictograms
3	Composition / ingredients	Chemical identity, CAS numbers, concentration ranges
4	First-aid measures	What to do after exposure: inhalation, skin, eyes, ingestion
5	Fire-fighting measures	Suitable extinguishing media, special hazards from combustion
6	Accidental release measures	Spill/leak procedures, containment steps, PPE needed
7	Handling and storage	Safe handling practices, incompatible materials, storage conditions
8	Exposure controls / PPE	OSHA PELs, ACGIH TLVs, required respiratory protection and gloves
9	Physical and chemical properties	Appearance, odor, pH, flash point, boiling point, vapor pressure
10	Stability and reactivity	Conditions to avoid, hazardous decomposition products
11	Toxicological information	Routes of exposure, LD50 values, carcinogenicity data
12	Ecological information	Environmental fate (not enforced by OSHA, but required by EPA)
13	Disposal considerations	Safe disposal methods and regulatory requirements
14	Transport information	DOT, IATA, IMDG hazard classes and UN numbers
15	Regulatory information	SARA 311/312 reporting, state right-to-know listings
16	Other information	Revision date, changes from previous version

Section 8 drives your PPE decisions. Section 2 gives you the signal word and pictograms at a glance. Section 4 is what your first-aiders need in the first 60 seconds after an incident. Train your people on those three first. The rest matters, but those three prevent injuries and save lives during an emergency.^[2]

What were the problems with the old MSDS format?

The old MSDS lived under 29 CFR 1910.1200 too, but the regulation only said what information had to be present, not how to organize it. That freedom caused real operational headaches.

A manufacturer in Germany might bury the emergency contact number on page 3. A domestic supplier might put it up top. Some sheets ran 2 pages, others ran 20. Some used jargon a chemist could parse and a warehouse worker could not. OSHA's own rulemaking pointed to these consistency problems as a reason to adopt GHS.^[1]

The inconsistency was more than annoying. In an emergency, a worker or a first responder hunting for the inhalation first-aid procedure should not have to skim an unstructured document line by line. The GHS fix was simple: first aid is always Section 4, always in the same spot. That single change is probably the most useful thing the 2012 revision did.

There was a trade problem too. A chemical shipped from a US company to a European customer, or the reverse, might arrive with a data sheet that did not match local format expectations. GHS built a shared framework across roughly 70 countries, which simplified compliance for importers and exporters.^[3]

What does OSHA require employers to do with SDSs today?

The employer duties under 29 CFR 1910.1200(g) are specific.^[2] You must:

1. Obtain an SDS for each hazardous chemical you use, in English (you can add translations, but English is required). 2. Keep SDSs accessible to employees during every work shift, in the areas where the chemicals are used or stored. 3. Make SDSs available to employees, their designated representatives, and OSHA inspectors on request.

Accessibility is the word that trips people up. OSHA allows electronic SDS systems, so you do not need a paper binder if workers can reach a terminal or tablet quickly and reliably. But the standard is blunt: if your system goes down, or workers cannot practically get to it during a shift, that is a violation. Plenty of small employers keep a paper backup in the break room or shop as insurance against tech failure. That is a smart call.

OSHA also expects you to keep SDSs for chemicals you no longer use, because of long-latency illnesses like occupational asthma and cancer. The standard sets no specific retention period, but 30 years is the number most safety pros follow, tied to the Access to Employee Exposure and Medical Records rule at 29 CFR 1910.1020.^[4]

Hazard Communication lands in OSHA's top 10 most-cited standards nearly every year. In fiscal year 2023 it ranked second across all industries, with 3,213 violations.^[5] Get your SDS management right, or an OSHA inspection will find the cracks fast.

How do you read and use an SDS in practice?

Most workers never read an SDS cover to cover, and they do not need to for routine work. What they need is to find specific information fast.

For daily work decisions, Section 8 is your map. It lists the permissible exposure limit (PEL), which is OSHA's regulatory limit, and often the ACGIH Threshold Limit Value (TLV), which is usually more conservative. It specifies the gloves, eye protection, respiratory protection, and other PPE the manufacturer recommends. That section drives your PPE selection and your hazard communication training content.

For spills and emergencies, teach people to go to Section 6 for spills and Section 4 for first aid. That is it. Those two sections cover the large majority of real-world incidents.

For storage decisions, Section 7 (handling and storage) and Section 10 (stability and reactivity) tell you which chemicals cannot sit next to each other. Hydrochloric acid, for example, cannot be stored with oxidizers. If you want to see a detailed SDS for a common industrial chemical, the HCl safety data sheet walks through how the 16 sections play out in a real document.

For regulatory reporting, Section 15 is where you check whether a chemical triggers Tier II reporting under SARA 311/312 or shows up on a state right-to-know list.

One habit worth building: when a new SDS arrives, check the revision date in Section 16 immediately. If it is more than a few years old, ask the supplier for a current version. Hazard classifications change as new toxicology data comes in, and you want current information driving your controls.

Who is required to create and provide SDSs?

Under 29 CFR 1910.1200(g)(1), chemical manufacturers and importers must prepare or obtain an SDS for each hazardous chemical they produce or import.^[2] Distributors must make sure an SDS travels with every shipment. Employers who neither manufacture nor import do not write SDSs themselves. Their job is to get them from suppliers and keep them accessible.

There are edge cases. If your company blends or mixes chemicals and then sells or transfers that mixture to workers at another facility, you may be acting as a manufacturer, which means you owe an SDS for the mixture. This comes up in agriculture, cleaning services, and specialty manufacturing.

29 CFR 1910.1200(b)(6) lists exempted materials. Consumer products used the same way and in the same quantities as a typical consumer (think dish soap at a break room sink) are generally exempt. Food, drugs, cosmetics, and tobacco products covered by other federal statutes are exempt too. Wood products in their natural state are exempt, though the wood dust generated during processing is not.^[2]

If you cannot get an SDS from a supplier, OSHA's interpretation letters make clear you have to make good-faith efforts and document them. Search the manufacturer's website or a public database. "We don't have one" is not an acceptable final answer.

How does an SDS connect to your written Hazard Communication program?

An SDS by itself does not make you compliant. The Hazard Communication Standard requires three pieces working together: a written program, labels on containers, and SDSs for every hazardous chemical.^[2] The SDS is the backbone of the written program, because it supplies the hazard information that flows into your training content and your chemical inventory.

Your written HazCom program has to include a chemical inventory list that ties each chemical to its SDS. OSHA does not dictate a format for that inventory, but it has to exist and stay current. If a new chemical shows up on your site and you do not have an SDS before workers start using it, that is a violation no matter how clean the rest of your binder is.

For small businesses that have not built this yet, the moving parts add up quickly. SafetyFolio's safety program generator walks you through a compliant written HazCom program by asking about the chemicals you actually use, instead of dropping you in front of a blank document.

Training is the third leg. 29 CFR 1910.1200(h) requires training when workers are first assigned to a job involving hazardous chemicals, and again whenever a new hazard shows up. That training has to cover how to read an SDS and find information in it, more than confirm that SDSs exist.^[2] Our guide on OSHA training requirements covers how to build that part of the program.

What GHS pictograms appear on SDSs and labels?

GHS created a standard set of nine pictograms, each a black symbol in a red diamond, to flag hazard categories at a glance. They appear on container labels and get described in Section 2 of the SDS.

Pictogram symbol (name)	Hazard categories it covers
Flame	Flammable liquids, solids, gases, self-reactives, pyrophorics
Flame over circle	Oxidizers
Exploding bomb	Explosives, self-reactives, organic peroxides
Skull and crossbones	Acute toxicity (fatal/toxic), categories 1-3
Exclamation mark	Irritants, acute toxicity cat. 4, skin/eye sensitizer, harmful
Health hazard (silhouette)	Carcinogen, mutagen, reproductive toxin, respiratory sensitizer, STOT
Corrosion	Skin corrosion, eye damage, corrosive to metals
Gas cylinder	Gases under pressure
Environment (tree/fish)	Aquatic toxicity (required by EPA, not OSHA)

The signal word in Section 2 is either "Danger" (the more severe categories) or "Warning" (less severe). A product carries only one signal word. If several hazards are present and any of them triggers "Danger," that word wins.^[3]

OSHA's Quick Card on GHS labels makes a handy one-page handout for toolbox talks.^[6]

Are employers fined for missing or outdated SDSs?

Yes, and the fines are real money. HazCom violations under 29 CFR 1910.1200 ranked second among all cited standards in OSHA's FY2023 data, with 3,213 violations.^[5]

OSHA classifies most HazCom violations as "other-than-serious," which carries a maximum penalty of $16,131 per violation as of January 2024, adjusted annually for inflation.^[7] A missing SDS for a single chemical is typically one violation. A missing SDS program with no training and no chemical inventory can draw several citations, each with its own penalty.

Willful or repeat violations, meaning you were cited before and did not fix the problem, reach maximum penalties of $161,323 per violation on the same schedule.^[7]

For small employers (under 25 workers), OSHA has a penalty reduction schedule that can cut the base penalty by up to 70 percent for good-faith effort, a clean history, and small size. The reduction applies to the dollar amount, not the finding. The citation still lands on your record.

Here is the practical part: inspectors often use HazCom as their opening move. If your SDS binder is a mess, they will dig harder into everything else. A clean HazCom program tends to set a calmer tone for the whole inspection.

Where can you find SDSs for free?

Start with the chemical supplier's website. Most major manufacturers keep a searchable SDS library. Type in the product name, pick your region (US), and download the current version. Keep the date.

If the supplier's site does not have it, or the company is gone, several public sources can help:

• OSHA's Hazard Communication page links to SDS resources and guidance.^[2]
• The National Institute for Occupational Safety and Health (NIOSH) publishes chemical hazard data through its Pocket Guide to Chemical Hazards, which covers about 700 common industrial chemicals and can supplement an SDS.^[8]
• CHEMTREC (chemtrec.com) runs a 24-hour emergency hotline and database, built for transportation emergencies but also useful for locating SDSs.
• Many state right-to-know programs keep SDS archives for chemicals reported under Tier II.

A few cautions. Third-party aggregator sites (not the manufacturer, not a .gov) can serve up stale versions. Always check the revision date in Section 16. If the copy you found was last updated in 2009, it predates GHS and almost certainly is not in the 16-section format, so request a current version from the manufacturer.

For a look at what current documentation reads like, the HCl safety data sheet article walks through one real chemical's data sheet in detail.

How do SDSs connect to other OSHA standards beyond HazCom?

The SDS does not stand alone. It is a data source that feeds requirements under several other OSHA standards.

29 CFR 1910.134, the Respiratory Protection standard, requires employers to evaluate whether airborne contaminants exceed the action level or PEL before picking a respirator. The PEL for a given chemical sits in Section 8 of its SDS. Without that section you cannot finish the exposure assessment.^[9]

Processes under the Process Safety Management standard at 29 CFR 1910.119 (facilities holding threshold quantities of highly hazardous chemicals) require a Process Hazard Analysis, and SDS data feeds straight into it. The threshold quantities for PSM chemicals tie to the same hazard classifications that show up in SDS Section 2.^[10]

The Emergency Action Plan standard at 29 CFR 1910.38 and HAZWOPER at 29 CFR 1910.120 both lean on chemical hazard information that starts in the SDS. Your spill response procedures should be built from Sections 6, 8, and 14 of the relevant chemical's SDS.

Lockout/tagout work sometimes involves hazardous energy that is chemical in nature. For those jobs, the SDS tells you what PPE fits during the lockout.

If you are building or reviewing your whole safety program and want to understand how OSHA structures general industry rules, 29 CFR 1910 subpart Z (toxic and hazardous substances) is where HazCom and most substance-specific standards live.

What should you do if workers speak limited English?

OSHA requires SDSs in English. The standard at 29 CFR 1910.1200(g)(2) does not stop you from adding other languages. English is the floor, not the ceiling.^[2] If part of your workforce speaks a primary language other than English, the practical and legal expectation is that training happens in a language those workers understand.

OSHA's training requirement at 29 CFR 1910.1200(h) uses the phrase "in a manner and language that their employees can understand." An inspector will ask whether workers in a non-English-speaking crew can actually explain what an SDS says and what they would do in an emergency. A binder of English-only SDSs with no translated training does not clear that bar for those workers.

Workable options: bilingual labels on secondary containers, translated summary cards for your most common chemicals, and toolbox talks run in Spanish or whatever language applies. Several chemical manufacturers now offer SDSs in multiple languages on request or through their web portals. OSHA itself publishes HazCom guidance materials in Spanish.^[11]

For OSHA 30 and OSHA training courses, providers increasingly offer Spanish-language options, which helps when you need to document formal HazCom training for non-English-speaking employees.

Frequently asked questions

Is an MSDS the same as an SDS?

They cover the same information but are not identical. An MSDS was the older, unstructured format used before OSHA's 2012 HazCom revision. An SDS is the current 16-section standardized format required under 29 CFR 1910.1200 since June 1, 2016. Old MSDS sheets are not compliant today. You need current 16-section SDSs from your suppliers.

How long do you have to keep SDSs after you stop using a chemical?

29 CFR 1910.1200 does not set a retention period for discontinued chemicals, but 29 CFR 1910.1020 (Access to Employee Exposure Records) requires keeping records of hazardous substance exposures for 30 years. Most safety professionals apply that 30-year standard to SDSs for chemicals workers were exposed to, as a conservative and defensible practice.

Can you store SDSs electronically instead of in a paper binder?

Yes. OSHA allows electronic SDS systems under 29 CFR 1910.1200(g), as long as employees can reach them during every work shift without barriers. If your system needs a password an employee does not have, or goes offline regularly, that is a compliance failure. Many employers keep a paper backup for the chemicals actually in use on the floor.

What happens if a supplier refuses to provide an SDS?

Put your request in writing and keep a copy. OSHA expects employers to make good-faith efforts to obtain SDSs and to document those efforts. If a supplier keeps refusing, you can file a complaint with OSHA. In the meantime, do not let workers use the chemical without hazard information. That itself is a HazCom violation.

Do SDSs cover mixtures or only pure chemicals?

Both. If a mixture is hazardous, its manufacturer must prepare an SDS for it as a mixture. Section 3 lists ingredient chemicals above a concentration threshold (generally 1 percent, or 0.1 percent for carcinogens), even when the mixture has a trade name that hides its composition. The SDS for the mixture is usually what you receive and use.

What is the difference between a PEL and a TLV on an SDS?

A PEL (Permissible Exposure Limit) is OSHA's enforceable legal limit for airborne chemical exposure, found in 29 CFR 1910.1000. A TLV (Threshold Limit Value) is a guideline published by ACGIH based on current research. It is not enforceable by OSHA but is often more conservative than older PELs. Both appear in SDS Section 8. Many industrial hygienists use TLVs as the more protective benchmark.

Do consumer products like cleaning supplies need an SDS at work?

If a cleaning product is used the same way and as often as a typical household consumer would use it, it may be exempt under 29 CFR 1910.1200(b)(6)(ix). But if workers use it in larger quantities, more frequently, or in ways that raise exposure beyond typical consumer use, the exemption drops and an SDS is required. When in doubt, get the SDS.

What is the GHS signal word 'Danger' versus 'Warning'?

'Danger' appears in Section 2 when a chemical falls into the more severe GHS hazard categories, such as flammable liquid Category 1 or acute toxicity Category 1-3. 'Warning' covers less severe categories. A product carries only one signal word. If any hazard triggers 'Danger,' that word is used. The signal word should also appear on the container label.

How often should SDSs be updated?

Chemical manufacturers must update an SDS within three months of learning significant new information about a hazard, per 29 CFR 1910.1200(g)(5). As an employer, check with suppliers periodically, especially for chemicals workers use daily. A practical trigger: whenever you renew a supply contract or receive a new lot, ask the supplier whether the SDS has changed since your last copy.

Can OSHA cite you for an SDS that is in the wrong format?

Yes. Since the June 1, 2016 deadline, an MSDS in the old unstructured format does not satisfy the SDS requirement under 29 CFR 1910.1200(g). Inspectors check both that an SDS exists and that it meets the 16-section format. A missing or non-conforming SDS is citable, usually classified as other-than-serious with a maximum penalty of $16,131 per instance as of 2024.

What is a secondary container label and does it need SDS information on it?

A secondary container is any container other than the manufacturer's original packaging, such as a spray bottle you fill from a bulk jug. Under 29 CFR 1910.1200(f)(6), secondary containers must be labeled with the product identity and appropriate hazard warnings. They do not need to reproduce the full SDS, but they must carry enough information to link back to it and alert workers to the hazard.

Does the SDS requirement apply to small employers with fewer than 10 workers?

Yes. The Hazard Communication Standard at 29 CFR 1910.1200 applies to any employer with workers who may be exposed to hazardous chemicals, with no employee-count exemption. Very small employers (under 10 employees) do get some OSHA recordkeeping exemptions, but HazCom is not one of them. Use any hazardous chemicals and you need SDSs, labels, a written program, and training.

Where is the OSHA standard that governs SDSs, exactly?

29 CFR 1910.1200 is the primary rule for general industry. Construction is covered under 29 CFR 1926.59, which incorporates 29 CFR 1910.1200 by reference. The SDS requirements are in paragraph (g), and the mandatory 16-section format is in Appendix D. The GHS hazard classification criteria live in Appendix A and Appendix B.

Sources

1. OSHA, Hazard Communication Final Rule (HazCom 2012), Federal Register March 26 2012: OSHA published the revised HazCom standard on March 26, 2012, aligning with GHS and introducing the 16-section SDS format with a June 1, 2016 full compliance deadline.
2. OSHA, 29 CFR 1910.1200 Hazard Communication Standard (including Appendix D): Mandates SDS requirements: 16-section format, employer duties to obtain and make accessible, training requirements, and chemical manufacturer obligations.
3. United Nations Economic Commission for Europe, Globally Harmonized System of Classification and Labelling of Chemicals (GHS): GHS standardized hazard classification, signal words (Danger/Warning), and pictograms across approximately 70 countries, forming the basis for OSHA's HazCom 2012 revision.
4. OSHA, 29 CFR 1910.1020 Access to Employee Exposure and Medical Records: Requires retention of records of employee hazardous substance exposures for 30 years, the basis for the 30-year SDS retention practice for discontinued chemicals.
5. OSHA, Top 10 Most Frequently Cited Standards, Fiscal Year 2023: Hazard Communication (1910.1200) was the second most cited OSHA standard in FY2023, with 3,213 violations across all industries.
6. OSHA, Hazard Communication Standard Pictogram and label Quick Cards: OSHA publishes a one-page Quick Card explaining the nine GHS pictograms and label elements, useful for toolbox talks.
7. OSHA, Penalties page, OSHA civil penalty amounts adjusted for inflation (January 2024): As of January 2024, OSHA's maximum other-than-serious penalty is $16,131 per violation; willful or repeat violations reach $161,323 per violation.
8. NIOSH, Pocket Guide to Chemical Hazards: NIOSH maintains a free database of chemical hazard information for approximately 700 common industrial chemicals, useful for supplementing SDSs.
9. OSHA, 29 CFR 1910.134 Respiratory Protection standard: Requires employers to evaluate airborne contaminant levels against PELs before selecting respirators; PEL data comes from SDS Section 8.
10. OSHA, 29 CFR 1910.119 Process Safety Management of Highly Hazardous Chemicals: PSM requires Process Hazard Analysis using chemical hazard information that originates in SDS documentation for covered threshold quantities.