Guide
SDS for Consumer Products: When Do You Need One?
Consumer products such as household cleaners, paints and glues are regulated mainly through their labels. OSHA's HazCom standard exempts a consumer product in the workplace only if the employer can show it is used for the purpose intended by its manufacturer, with no greater duration and frequency of exposure than a consumer could reasonably experience. Industrial or heavy use means you need a sheet, and most manufacturers supply one on request.
Last updated by SDS Lookup
Two regulatory worlds
Products sold to the public fall under consumer product laws. In the US, the Consumer Product Safety Commission enforces the Federal Hazardous Substances Act, which sets cautionary labeling for hazardous household products. These labels use signal words and statements, but the rules differ from OSHA's HazCom labels. A consumer label is designed for a person using the product occasionally at home. An SDS is designed for workers who use a product regularly.
The workplace exemption
HazCom contains an exemption for consumer products. It applies when the employer can show two things: the product is used in the workplace for the purpose intended by the chemical manufacturer or importer, and the use results in a duration and frequency of exposure that is not greater than the range of exposures that could reasonably be experienced by consumers using it for that purpose (29 CFR 1910.1200(b)(6)(ix)). A receptionist who occasionally wipes a desk with a spray bottle is a fair example. A janitorial team that uses the same cleaner for hours every night is not, because the exposure is more intense.
Because the exemption depends on your use, it is safer to treat the product as covered when in doubt. Obtain the sheet, include the product in your chemical inventory and train employees.
How to find an SDS for a consumer product
- Search the manufacturer's website. Many publish sheets in a "safety" or "support" section.
- Use the product code or barcode when the same brand has several versions.
- Call or email customer service. Request the "SDS" and say you are using it for workplace purposes.
- Check the retailer. Some retailers host sheets for products they sell.
- Use a database of public chemical data to look up the main ingredients; our chemical index is one starting point. Note that this is a substitute only for understanding ingredient hazards, not for the product's own sheet.
See how to get an SDS from a manufacturer for a template request.
Ingredient disclosure on consumer products
Consumer product labels do not always list every ingredient. Some jurisdictions and industry programs require or encourage ingredient disclosure for cleaning and personal care products, but the scope varies. A workplace SDS typically provides more detail under Section 3 than a consumer label, including the hazardous ingredients and their concentrations or ranges. Read how it works in Section 3.
Safe use tips for products at home
- Follow the label directions. Do not mix cleaners. Combining bleach with acids or ammonia-based products can release toxic gases; the label usually warns of this.
- Keep products in their original containers.
- Store them out of reach of children and pets.
- Ventilate when using strong-smelling products.
- In an emergency call your local emergency number; in the US, Poison Help is 1-800-222-1222.
The storage compatibility guide explains why certain products should not be stored together.
Worked scenario: a cleaner used by a janitorial team
A building services company buys a popular household spray cleaner from a retail store because it works well. A single office worker wiping a desk once a day plausibly uses it for its intended purpose with consumer-like exposure. A night crew spraying it on surfaces for several hours is not, because the duration and frequency of exposure are greater than what a household would experience. The company should therefore treat it as a hazardous chemical in the workplace: get the sheet from the manufacturer, add it to the inventory, label any decanted bottles and train the crew.
The same logic applies to paints, adhesives and aerosol products. Ask whether the way you use the product at work differs from how a consumer would, and if so assume HazCom applies.
Questions to ask the manufacturer
- Do you have an SDS in the 16-section format for this exact product?
- Is the product classified as hazardous for workplace purposes?
- Does an industrial or professional version of the product exist with fuller documentation?
- What is the emergency contact number for the product?
Frequently asked questions
Does every household product have an SDS?
Not every product has a published SDS, but many manufacturers have one and will provide it on request. Products that are not hazardous may not have one.
Do I need an SDS for cleaning products at work?
Often yes. The consumer product exemption applies only if you use the product for its intended purpose and your duration and frequency of exposure are no greater than a consumer's. Heavy or frequent use needs a sheet.
Is a consumer product label the same as a GHS label?
No. Consumer labels follow consumer product law, such as the Federal Hazardous Substances Act in the US. Workplace labels follow HazCom and include GHS pictograms, signal word and statements.
What if the manufacturer will not provide a sheet?
Ask in writing, record the request, and consider switching to a product with full documentation. OSHA's local office can help if you cannot obtain a sheet for a hazardous chemical.