How Long Should You Keep SDS Records?

Two standards, two purposes

The Hazard Communication Standard (29 CFR 1910.1200) requires employers to maintain an SDS for each hazardous chemical in the workplace and make it accessible. It does not state how long a replaced or discontinued sheet must be kept. The retention question is answered by 29 CFR 1910.1020, Access to employee exposure and medical records, which governs records of employee exposure to toxic substances and harmful physical agents.

Under that standard, employee exposure records must generally be preserved for 30 years. A sheet can count as part of an exposure record because it documents the identity and hazards of what employees worked with.

The alternative to keeping every sheet

The records access standard recognises that keeping every old sheet forever is a burden. It allows an employer to discard an old SDS if the employer instead keeps a record of the identity of the chemical, where it was used and when it was used, and keeps that record for 30 years. This is why many companies maintain a chemical inventory with dates and locations in addition to their current SDS library.

If you rely on this approach, make sure the record is specific enough that a worker, a physician or an investigator could later work out which substances were present, in which area and in what time period. A list that only shows the current month is not enough. See chemical inventory management for how to structure it.

What most employers do in practice

• Keep the current sheet for every chemical in use, accessible to all employees on every shift.
• When a sheet is replaced, archive the old one, with the date it was in use, in a retained archive.
• Maintain an inventory log showing the chemical, the location, and the dates of use.
• Store archives so that they can be retrieved, either electronically with backups or in paper form.
• Define who is responsible for the archive, including when staff change or the company is sold.

Other records connected to SDSs

Retention periods apply to other documents too. Training records, medical records and monitoring data each have their own rules, and some states have additional requirements. Medical records have a separate retention rule in the same standard: generally the duration of employment plus 30 years. If you are unsure, check the text of the standard or ask your OSHA state plan office. Do not guess at specific periods for documents other than those you can verify.

Outside the US the rules differ. In the EU, for example, REACH asks suppliers to keep information for a minimum period, and national laws on occupational health records also apply. This guide covers the US approach only.

Access rights

Employees, their designated representatives and OSHA can ask to see exposure records. The standard sets time limits for the employer to respond, generally 15 working days. So records that are kept must also be findable. A poorly organized archive that cannot be searched may not satisfy the access requirement even if the paper exists. See employee right to know.

Worked scenario: a request ten years later

A former employee asks for information about the chemicals they worked with in a particular area a decade ago. The company has changed suppliers twice since then. If the company kept only current sheets, it cannot answer. If it kept either the old sheets or an inventory record showing the identity of each chemical, where and when it was used, it can reconstruct the exposure history and provide the information when asked. This is the situation the 30-year provisions are designed for.

Frequently asked questions