OSHA Material Safety Data Sheets MSDS

Employers’ Responsibilities

Safety data sheets (SDSs) – formerly called “material safety data sheets” or MSDSs prior to OSHA's 2012 revision of the Hazard Communication Standard to align with the UN's Globally Harmonized System (GHS) – are forms that must be filled out by every manufacturer, importer, and distributor of chemicals for every substance that may pose a health hazard in the workplace, as defined in the Act.  Since the GHS-aligned standard took full effect, SDSs must follow a specified, uniform 16-section format so the same type of information always appears in the same place.

Under the Hazard Communication Standard, employers must maintain a complete and accurate SDS for each hazardous chemical used in the facility.  If employers do not receive SDSs with chemical shipments, it is the employer’s duty to contact the manufacturer for clarification or to obtain the missing information.  If chemical manufacturers are uncooperative, employers can contact the nearest OSHA area office.

Over-the-counter purchases.  OSHA notes that employers often purchase so called hazardous substances from retailers, which may not have SDSs available.  In such cases, the employer should obtain the name and address of the manufacturer or distributor of the chemicals from the retailer and contact the manufacturer to obtain SDSs.

Employee communication.  Employers must make SDSs readily available to employees who may be exposed to the hazardous substances during the course of work.  Employers must also make sure each employee has a basic knowledge of the SDS and how to use the information.  The standardized 16-section SDS format adopted under the GHS-aligned Hazard Communication Standard is intended to make SDSs easier to read and to make safety training more effective.

Labeling Requirements

Manufacturers, importers, and distributors must also label shipped containers of hazardous substances.  Under the GHS-aligned standard, labels must include standardized elements: a product identifier, signal word (“Danger” or “Warning”), pictogram(s), hazard statement(s), precautionary statement(s), and the name and address of the manufacturer or other responsible party.  Employers are responsible for ensuring that all containers of hazardous substances are properly labeled, including temporary storage containers used but not provided by the manufacturer (workplace labels on such containers may use these GHS elements or other alternative labeling systems, such as words, pictures, or symbols, that convey the same information).

Training Requirements

the requirements of the Hazard Communication Standard; any operations in employees’ work areas where hazardous chemicals are present; location and availability of the company’s hazard communication program, including the required SDSs; physical and health hazards of the chemicals in the work area; measures employees can take to protect themselves from these hazards, including information on work practices, emergency procedures, and the personal protective equipment required by the employer; and details of the employer’s written hazard communication program, including an explanation of the labeling system, SDSs, and how employees can use the appropriate hazard information on the labels and SDSs. Training Tip.  The Committees on Occupational Safety and Health (COSH) have found these suggestions helpful when training employees in the Hazard Communication Standard:

  • Try to train in small groups of three to five people, sitting around a table rather than in classroom style.  Participants will help one another around the table and ask questions within their small group, rather than embarrassing themselves by raising their hands.
  • Gauge the participant’s pace in learning, and adjust the presentation accordingly
  • Use simple terms.  For example “Acute” means now; “Chronic” is a longer term.
  • Lighten the presentation with anecdotes and humor.  Use case histories right from the organization if possible.
  • Take a break every half-hour.

General information, not legal advice. Treat this as a drafting starting point, not a finished policy — employment law varies by jurisdiction and changes often, so have a licensed attorney tailor it to your situation before you rely on it.