MSDS and safety data sheets: what every employer must know

Last updated 2026-07-09

What is an MSDS, and is it still the right term?

MSDS stands for Material Safety Data Sheet. For decades it was the standard name for the document that tells workers what a chemical is, how it can hurt them, and what to do if something goes wrong. OSHA retired the term in 2012.

In May 2012 OSHA revised its Hazard Communication Standard at 29 CFR 1910.1200 to align with the United Nations Globally Harmonized System of Classification and Labelling of Chemicals, commonly called GHS. Under that revision, the document became a Safety Data Sheet (SDS), and the format changed from a flexible, manufacturer-defined layout to a strict 16-section structure. ^[1]

So if someone hands you a document labeled "MSDS," it is probably out of date. It may still contain useful information, but it predates the standardized format. You should be working from current SDSs that follow the 16-section GHS template. Most chemical suppliers have updated their documents, but older products, especially from small manufacturers, sometimes lag behind.

The short version: MSDS and SDS describe the same type of document. MSDS is the pre-2012 label. SDS is what OSHA requires now. You will still see "MSDS" everywhere online because search traffic is enormous and old documents persist, but in a compliance context always use SDS.

When did OSHA switch from MSDS to SDS, and what actually changed?

OSHA published the revised Hazard Communication Standard on March 26, 2012, with a phased compliance schedule. Chemical manufacturers and importers had to train workers on the new label and SDS format by December 1, 2013. Distributors had to comply by December 1, 2014. By June 1, 2016, all employers had to update their written hazard communication programs and have GHS-compliant SDSs on file. ^[1]

The content changes were big. Old MSDS documents had no required order of sections. A manufacturer could put physical hazard data on page one or page four. There was no agreed-upon spot for emergency contacts or toxicology data. That inconsistency made it hard for workers and emergency responders to find what they needed fast.

GHS fixed that by mandating exactly 16 sections in a fixed sequence. Every SDS from every manufacturer in every GHS-adopting country now has the same skeleton. A firefighter responding to a warehouse incident in Ohio and a worker in Germany read the same section numbers for the same types of information. ^[2]

The second big change was hazard classification. GHS introduced standardized hazard categories with specific signal words ("Danger" vs. "Warning"), pictograms, and hazard statements. The old MSDS might say "moderately flammable." A current SDS says "Flammable liquid, Category 2" and shows the flame pictogram. That specificity matters when you are writing a hazard communication program and need to match controls to hazard categories.

What are the 16 sections of a GHS safety data sheet?

The 16-section structure is defined in 29 CFR 1910.1200, Appendix D. Each section has a required name and required content. Here is what each one covers:

Section	Name	Key content
1	Identification	Product name, manufacturer, emergency phone
2	Hazard(s) identification	GHS classification, signal word, pictograms, hazard statements
3	Composition/information on ingredients	CAS numbers, chemical names, concentrations
4	First-aid measures	What to do after exposure by route (skin, eyes, inhalation, ingestion)
5	Fire-fighting measures	Extinguishing agents, special hazards, PPE for firefighters
6	Accidental release measures	Containment, cleanup, environmental precautions
7	Handling and storage	Safe handling practices, incompatible materials, storage conditions
8	Exposure controls/personal protection	OSHA PELs, ACGIH TLVs, required PPE, engineering controls
9	Physical and chemical properties	Appearance, odor, flash point, boiling point, vapor pressure, etc.
10	Stability and reactivity	Conditions to avoid, incompatible materials, hazardous decomposition
11	Toxicological information	Routes of exposure, symptoms, LD50 values if known
12	Ecological information	Environmental fate (required by GHS, not enforced by OSHA)
13	Disposal considerations	Waste disposal methods
14	Transport information	DOT, IATA, IMDG classifications
15	Regulatory information	Other applicable regulations
16	Other information	Revision date, preparation date, SDS version number

A practical note: OSHA does not enforce Sections 12 through 15 because they fall under other agencies (EPA, DOT, and others). But manufacturers include them, and Section 14 is genuinely useful if you ship hazardous materials. ^[3]

For day-to-day safety management, Sections 2, 4, 8, and 10 are the ones workers need to find quickly. Section 8 is where you pull PPE requirements for your written program. Section 2 gives you the hazard classification for your chemical inventory list.

What are employers legally required to do with safety data sheets?

The requirements come from 29 CFR 1910.1200, the Hazard Communication Standard. The rule applies to any workplace where employees may be exposed to hazardous chemicals. ^[1]

The specific employer duties are:

First, you must obtain an SDS for each hazardous chemical you use or store before that chemical enters the workplace. If a supplier does not provide one, you are required to request it. OSHA's position is that you cannot accept a chemical without an SDS from the manufacturer or importer.

Second, SDSs must be readily accessible to employees during their work shift. OSHA's language in the standard is specific: "readily accessible" means employees can get to them without having to ask a supervisor and without delays. Electronic access is allowed, but only if there is always a backup when systems are down. OSHA has issued letters of interpretation confirming that a computer system without a reliable backup does not meet the standard. ^[4]

Third, you cannot charge employees for accessing SDSs, and you cannot require employees to ask management before looking at them.

Fourth, you must train employees on how to read and use SDSs. Training is required before initial assignment to a job involving hazardous chemicals and whenever a new chemical hazard is introduced. The osha training requirements for HazCom are part of the same standard.

Fifth, your written hazard communication program must describe how you manage SDSs, including where they are kept and how employees access them. If you do not have a written HazCom program yet, that is a more urgent gap than the SDS files themselves, because OSHA inspectors ask for the written program first.

For the general industry standard the citation number is 29 CFR 1910.1200. Construction follows 29 CFR 1926.59, which incorporates HazCom by reference.

How do you find a safety data sheet (SDS lookup)?

There are several reliable ways to do a safety data sheet lookup, and most are free.

The manufacturer's website is always the best first stop. Go to the product page or search for "[product name] SDS" in the site's search. Most chemical manufacturers keep SDS libraries because they are legally required to in multiple countries. Download directly from the source and note the revision date. If the SDS is more than a few years old, check whether a newer version exists.

Free databases worth bookmarking:

OSHA's site does not maintain a full SDS database itself. The better government source for chemical data is the NIOSH Pocket Guide to Chemical Hazards, available at cdc.gov, which covers hundreds of common industrial chemicals with exposure limits and health data. ^[5]

The National Library of Medicine's PubChem database has chemical data for thousands of substances, including many with linked SDSs or similar safety summaries. PubChem's Safety and Hazards section often mirrors GHS classification data from manufacturers. ^[6]

For common lab and industrial chemicals, Sigma-Aldrich (now part of MilliporeSigma) keeps one of the most complete free SDS libraries online. Fisher Scientific, VWR, and Grainger all publish SDSs for products they sell. These are legitimate documents you can use even if you did not buy the chemical from that specific supplier, as long as the formulation matches.

For an hcl safety data sheet specifically (hydrochloric acid is one of the most searched chemicals), concentration matters enormously. A 37% HCl solution has very different hazard classifications and exposure limits than a 10% solution. Always confirm the concentration on the container matches the SDS you are using.

If you cannot find an SDS after a reasonable search, contact the chemical's manufacturer directly. They are legally required under 29 CFR 1910.1200(g) to provide one. Document your request in writing.

What do OSHA PELs and TLVs in Section 8 actually mean?

Section 8 of every SDS lists exposure limits, and there are usually two sets of numbers sitting next to each other. The difference matters when you pick controls.

OSHA Permissible Exposure Limits (PELs) are legally enforceable. They come from 29 CFR 1910.1000, Table Z-1 for general industry, and they set the maximum airborne concentration of a substance most workers can be exposed to over an 8-hour workday, 40-hour workweek, without harm. The problem with OSHA PELs is that most of them date to 1971 and have not been touched since. OSHA tried to update them in bulk in 1989 but a court struck that rulemaking down. ^[7] The agency has updated individual substance standards since, but most Z-1 limits are decades old.

ACGIH Threshold Limit Values (TLVs) are published by the American Conference of Governmental Industrial Hygienists and updated every year. They are not legally enforceable by OSHA, but they reflect more current science than PELs. NIOSH also publishes Recommended Exposure Limits (RELs) that are often more protective than PELs.

Here is how it plays out in practice. An industrial hygienist or a cautious safety manager making control decisions will often use the lowest of the PEL, TLV, and REL. If you are purely in compliance mode, the PEL is the line you cannot cross. If you are trying to actually protect workers rather than just dodge citations, the TLV is usually the better target.

Section 8 also lists required engineering controls (ventilation, enclosure) and PPE. This is the section you copy from when writing PPE requirements into your chemical-specific procedures. The relevant PPE standards at OSHA run from 29 CFR 1910.132 through 1910.140.

How often do safety data sheets need to be updated?

The short answer: whenever the hazard information changes.

OSHA's standard at 29 CFR 1910.1200(g)(5) requires manufacturers and importers to update an SDS within three months of learning of new and significant information about the hazards of a chemical or ways to protect against those hazards. ^[1] There is no fixed annual or biennial update requirement for a chemical that has not changed.

As an employer, your obligation is to hold the most current SDS. Practically, that means checking with your supplier from time to time, especially for chemicals you have used for years. A 2010-dated SDS for a product that went through GHS revision has almost certainly been superseded.

Look at Section 16 of any SDS. It must include the preparation or last revision date. If you have a document with no date, that is itself a compliance problem, because 29 CFR 1910.1200, Appendix D, Section 16 requires it.

For products where the formulation changed, the supplier is supposed to send you a revised SDS. In practice, that does not always happen on its own. Building a supplier check into your annual program review is the reliable fix.

What are the OSHA penalties for SDS violations?

Hazard communication is consistently one of the top three most-cited OSHA standards every year. In fiscal year 2023, 29 CFR 1910.1200 was the second most frequently cited standard in federal OSHA inspections, with 3,213 violations. ^[8]

Penalty amounts depend on how the violation is classified. As of 2024, OSHA maximum penalties are:

Violation type	Maximum penalty per violation
Serious	$16,131
Other-than-serious	$16,131
Willful or repeated	$161,323

OSHA adjusts these figures annually for inflation under the Federal Civil Penalties Inflation Adjustment Act. The figures above are the 2024 ceiling. ^[9]

The HazCom violations auditors actually cite: no SDS for a chemical on site, SDSs not accessible during all shifts (locked cabinet, system down with no backup), no written HazCom program, and employees not trained on how to read SDSs. Missing a single SDS tends to be cited as a serious violation. A pattern of missing SDSs combined with no written program can draw a willful classification.

OSHA also runs a Severe Violator Enforcement Program that flags employers for enhanced follow-up inspections after willful or repeated violations. You do not want to be on that list.

Small employers (10 or fewer employees) can sometimes get penalty reductions, and OSHA's On-Site Consultation Program offers free inspections that do not result in citations. That program is walled off from enforcement. ^[10]

How do you build an SDS management system that actually works?

Most OSHA citations here are not because employers do not care. They happen because the SDS system got set up once and never maintained. Here is what a working system looks like.

Start with a chemical inventory. Every SDS system begins with a complete list of hazardous chemicals on site. Walk every storage area, every maintenance closet, every cleaning supply cabinet. Owners are routinely surprised by how many products pile up. The inventory list is also required by your written HazCom program.

Decide on paper vs. electronic. Both are fine under OSHA, but electronic systems need a reliable backup. A binder in the break room is simple and never crashes. A system like eRPortal, 3E Protect, or even a well-organized shared drive works if you have IT support. The point is that a worker on the night shift can pull any SDS in under two minutes without calling anyone.

Assign ownership. Someone has to be responsible for requesting SDSs when new chemicals arrive, updating binders when revised sheets come in, and auditing the inventory once a year. In a small business this is often the owner or ops manager. Write the responsibility into the job description.

Pair SDSs with your written programs. When you write procedures for a specific chemical, reference the SDS section numbers that back each requirement. Section 8 feeds your PPE requirements. Section 7 feeds your storage requirements. Section 10 tells you what to keep it away from. If you are building a written hazard communication program and want to move faster, SafetyFolio's safety program generator can build the framework in about 15 minutes, then you populate it with your specific chemical list and SDS locations.

Train workers on what the SDS actually says. HazCom training means explaining each section's purpose, not handing out a binder. Workers should be able to locate the correct SDS, read the Section 2 hazard classification, and spot the PPE required in Section 8. Document that training with dates and signatures.

For lockout tagout programs, SDSs for hydraulic fluids, coolants, and cleaning solvents used during maintenance often feed directly into the energy control procedures for that equipment.

Are there special SDS rules for specific industries or chemicals?

The general HazCom standard at 29 CFR 1910.1200 covers most general industry and construction employers. But several categories carry extra or overlapping requirements.

Hazardous waste operations and emergency response (HAZWOPER, 29 CFR 1910.120) adds requirements for employers whose workers handle uncontrolled hazardous substances at cleanup sites. Those workers need SDSs available in the field and more training than standard HazCom requires.

Process Safety Management (PSM, 29 CFR 1910.119) applies to facilities with highly hazardous chemicals above threshold quantities. At a PSM-covered facility, SDSs are just one input into a much more detailed process hazard analysis. The PSM standard's list of covered chemicals and threshold quantities is in Appendix A of 29 CFR 1910.119.

The laboratory standard (29 CFR 1910.1450) covers employees who work with hazardous chemicals in lab settings. It modifies the HazCom requirements slightly, allowing a chemical hygiene plan to substitute for the full written HazCom program, but SDSs are still required.

DOT transportation rules add a layer on top of OSHA when chemicals move off site. Section 14 of every SDS gives the DOT proper shipping name, UN number, and packing group. If your workers load outbound shipments of hazardous materials, they need training under 49 CFR Part 172 Subpart H, beyond HazCom.

For pesticides used in agriculture, the EPA requires Safety Data Sheets under its Worker Protection Standard (40 CFR Part 170) as well, with specific posting requirements near application sites.

The floor is 29 CFR 1910.1200. Depending on your industry, there may be a higher standard sitting on top of it.

What if you receive a chemical with an MSDS instead of an SDS?

This still happens. Older products, surplus chemicals, and purchases from small foreign manufacturers sometimes arrive with a pre-2012 MSDS document.

Here is the honest answer. An MSDS that contains the required information is not automatically useless, but it does not meet OSHA's current documentation requirement, which specifies the 16-section GHS format under 29 CFR 1910.1200, Appendix D. You are supposed to have a current SDS.

Your first step is to contact the manufacturer or importer and request a current GHS-compliant SDS. They are legally required to provide one. If they cannot or will not, that is a signal worth taking seriously before you use the product.

If you are in a pinch and need to work with the chemical before a current SDS arrives, you can check whether the chemical's hazards appear in the NIOSH Pocket Guide or PubChem, and document that you made the request in writing. That is a stopgap, not a long-term solution.

For chemicals where the manufacturer has gone out of business or is otherwise unreachable, the NIOSH Pocket Guide, OSHA's Chemical Sampling Information database, and the CAMEO Chemicals database (from NOAA and EPA) can supply hazard information for many common substances. Those are not SDSs in the regulatory sense, but they support protective decisions while you track down a compliant document or switch to a product with better documentation. ^[5]

How does SDS management fit into a broader written safety program?

SDS management on its own is not a safety program. It is one required piece of a hazard communication program, which is itself one element of an overall written safety program.

OSHA's Recommended Practices for Safety and Health Programs describe SDS accessibility as part of the "hazard identification and assessment" element. ^[10] The idea is simple: you cannot control a hazard you have not characterized, and the SDS is your primary characterization document for purchased chemicals.

In practice, a complete written program covering hazardous chemicals has a hazard communication section (chemical inventory, SDS management, labeling), a training section (who trains whom, on what, documented how), a PPE section that references Section 8 of relevant SDSs, and emergency procedures that reference Sections 4 through 6.

If you are also dealing with energized equipment near chemical storage, your lockout tagout procedures should cross-reference the relevant SDSs. If a worker has been injured and you are filing an incident report, the SDS for any chemical involved belongs in the investigation documentation.

The honest reality for small businesses is that building all of this from scratch eats time. A tool like SafetyFolio's safety program generator gives you a structured starting point, and then you customize it with your actual chemical list, SDS locations, and employee names. That beats downloading a generic template and filing it away unread.

Frequently asked questions

Is MSDS the same as SDS?

Yes, they describe the same type of document. MSDS (Material Safety Data Sheet) is the pre-2012 term. OSHA renamed it Safety Data Sheet (SDS) when it revised the Hazard Communication Standard in 2012 to align with the UN's GHS system. The content requirements also changed significantly: SDS documents must now follow a mandatory 16-section format that older MSDS documents did not use.

Where can I find a free safety data sheet for a specific chemical?

Start with the manufacturer's website. For common chemicals, the free databases at PubChem (pubchem.ncbi.nlm.nih.gov), Sigma-Aldrich, and Grainger are reliable. The NIOSH Pocket Guide at cdc.gov/niosh covers hundreds of industrial chemicals with hazard summaries. For emergency response, the NOAA CAMEO Chemicals database is free and well-maintained. Always confirm the concentration and formulation on your container matches the SDS you download.

How many SDSs do I need to keep on file?

One for each hazardous chemical present in your workplace. There is no minimum number in the regulation; the requirement is coverage. Walk your facility and build a chemical inventory first. Many small businesses are surprised to find 40 to 80 products when they include cleaning supplies, maintenance chemicals, lubricants, and process materials. Every item on that inventory needs a current, GHS-format SDS accessible to workers on every shift.

Can I store safety data sheets electronically?

Yes. OSHA explicitly allows electronic SDS systems. The requirement is that employees can access any SDS immediately during their work shift without asking a supervisor. Electronic systems must have a reliable backup for outages. OSHA has issued letters of interpretation stating that a computer-only system with no backup fails the "readily accessible" standard. A printed backup binder for the most common chemicals satisfies the backup requirement in most inspections.

What is the penalty for not having an SDS?

Missing an SDS is typically cited as a serious violation under 29 CFR 1910.1200, with a maximum penalty of $16,131 per violation as of 2024. A pattern of missing SDSs or a complete absence of a hazard communication program can escalate to willful classification, with penalties up to $161,323 per violation. HazCom was the second most frequently cited OSHA standard in FY2023, with 3,213 violations cited in federal inspections.

Do I need SDSs for consumer products used in the workplace?

It depends on how you use them. OSHA's HazCom standard exempts consumer products used in the workplace in the same way and frequency that a consumer would use them at home. If workers use a product more frequently, in larger quantities, or in ways that create greater exposure than a typical consumer, the exemption does not apply and you need an SDS. When in doubt, get the SDS. The cost of having it is zero; the cost of not having it is a potential citation.

How long do I have to keep old safety data sheets?

OSHA's HazCom standard itself does not specify a retention period for superseded SDSs. However, if a chemical was used in your workplace and an employee later develops an occupational illness, you may need historical SDSs as evidence. OSHA's medical records rule at 29 CFR 1910.1020 requires retaining employee exposure records, which includes SDSs for substances employees were exposed to, for 30 years. Keeping old SDSs indefinitely is the safest approach.

What is a GHS pictogram and where does it appear on an SDS?

GHS pictograms are standardized symbols inside a red diamond border that communicate hazard categories visually. There are nine: flame, flame over circle, exploding bomb, corrosion, gas cylinder, skull and crossbones, exclamation mark, health hazard, and environment. They appear on the chemical label and are listed in Section 2 of the SDS under hazard identification. Workers should be trained to recognize them as part of their HazCom training under 29 CFR 1910.1200(h).

What is the difference between an SDS and a chemical label?

Both are required by OSHA's HazCom standard but serve different purposes. The label on the container gives immediate hazard information at the point of use: product identifier, signal word, pictograms, hazard statements, and precautionary statements. The SDS gives detailed technical information for longer reference: exact composition, exposure limits, detailed first aid, firefighting procedures, and disposal. The label points you to the SDS when you need more information.

Do safety data sheets expire?

There is no formal expiration date, but SDSs must be updated within three months whenever the manufacturer learns of new significant hazard information. Section 16 of every SDS must show the preparation or last revision date. As an employer, you should periodically verify you have the manufacturer's current version, especially for chemicals you have used for many years. A document with no revision date does not meet Appendix D requirements.

Are there SDS requirements for mixtures vs. pure chemicals?

Yes, and mixtures are more complex. For a mixture, the SDS must list ingredients that are classified as health hazards if they exceed specific concentration thresholds (typically 1% by weight, or 0.1% for carcinogens). The manufacturer must classify the mixture's overall hazard, which requires either testing data for the mixture or applying bridging principles from component data. Section 3 of the SDS for a mixture will show ingredients and their concentration ranges, though exact percentages can be listed as ranges to protect trade secrets.

Can my supplier withhold chemical ingredients as a trade secret?

Yes, within limits. Under 29 CFR 1910.1200(i), manufacturers can withhold the specific chemical identity of a trade secret ingredient on the publicly available SDS. However, they must still disclose the health hazards associated with that ingredient. Healthcare providers treating an exposed employee can request the trade secret identity in a medical emergency, and it must be provided immediately. OSHA can also require disclosure upon showing a need.

What training do employees need on safety data sheets?

Under 29 CFR 1910.1200(h), employees must be trained before initial assignment to work with hazardous chemicals and when new hazards are introduced. Training must cover how to read and use SDSs, the meaning of hazard classifications and pictograms, how to access SDSs during their shift, and the physical and health hazards of chemicals they work with. Training must be documented. Refresher training is required when new chemical hazards are introduced, not necessarily on a fixed annual schedule.

What is the NIOSH Pocket Guide and how does it relate to SDSs?

The NIOSH Pocket Guide to Chemical Hazards is a free reference published by the National Institute for Occupational Safety and Health, available at cdc.gov/niosh. It covers chemical and physical properties, exposure limits (OSHA PELs, NIOSH RELs, ACGIH TLVs), and health effects for hundreds of common workplace chemicals. It is not an SDS and does not replace one, but it is the fastest authoritative source for checking whether an SDS exposure limit is current or outdated.

Sources

1. OSHA, 29 CFR 1910.1200 Appendix D - Minimum Information for an SDS: Appendix D defines the required content of all 16 SDS sections, including that Sections 12-15 are required but not enforced by OSHA.
2. NIOSH, Pocket Guide to Chemical Hazards: The NIOSH Pocket Guide provides exposure limits and health data for hundreds of common industrial chemicals and is a free authoritative reference for employers.
3. National Library of Medicine, PubChem: PubChem provides GHS classification data and linked SDSs for thousands of chemical substances, accessible free of charge.
4. OSHA, Permissible Exposure Limits (PELs) - 29 CFR 1910.1000 Table Z-1: Most OSHA PELs date to 1971; a 1989 bulk update was vacated by a court, leaving the majority of Z-1 limits based on decades-old science.
5. OSHA, Top 10 Most Cited Standards FY2023: 29 CFR 1910.1200 (Hazard Communication) was the second most cited OSHA standard in FY2023 with 3,213 violations in federal inspections.
6. OSHA, Penalties: As of 2024, the maximum penalty for a serious or other-than-serious violation is $16,131 and for willful or repeated violations is $161,323, adjusted annually for inflation.
7. OSHA, Recommended Practices for Safety and Health Programs: OSHA's recommended practices describe SDS accessibility as part of hazard identification and assessment, and the On-Site Consultation Program offers free inspections without citations for small employers.
8. OSHA, 29 CFR 1910.1020 - Access to Employee Exposure and Medical Records: SDSs for substances employees were exposed to are employee exposure records under 29 CFR 1910.1020 and must be retained for 30 years.
9. OSHA, HazCom Trade Secrets - 29 CFR 1910.1200(i): Manufacturers may withhold specific chemical identities as trade secrets on SDSs but must disclose health hazards and provide identity to healthcare providers in medical emergencies.
10. NOAA/EPA, CAMEO Chemicals Database: CAMEO Chemicals is a free government database for chemical hazard and response information, useful when a manufacturer SDS is unavailable.