SDS Update Requirements: How Often Must a Sheet Change?

What triggers an update

• New toxicity or ecotoxicity data, for example from a new study.
• A change in the product's formulation or ingredients.
• A change in classification criteria or in the regulatory standard, such as a revision of the HazCom standard or GHS.
• New or changed exposure limits.
• Updated transport rules or regulatory listings (see Section 15).
• Error corrections.

The supplier decides when information is "significant", but regulators and customers expect updates whenever the hazard picture changes.

The three-month rule and what comes with it

The standard requires the preparer to add significant new information to the sheet within three months of becoming aware of it (29 CFR 1910.1200(g)(5)), and to revise labels within six months ((f)(11)). Distributors must pass on the revised sheet. Employers must replace the old sheet in their library and tell employees if the changes affect them. The update date appears in Section 16.

Other jurisdictions are more specific. Australian rules require manufacturers and importers to review the sheet at least once every five years, and EU rules require updates without delay when new hazard or risk management information arises and when an authorisation is granted or refused or a restriction imposed. See Australia WHS and EU REACH.

What employers must do when a new sheet arrives

1. Read the change summary in Section 16, if provided, and compare Sections 2, 8 and 7 with the old sheet.
2. Replace the old sheet in your library, and archive the old one according to your retention plan; see how long to keep SDS records.
3. Check the label. If the hazard classification changed, workplace labels may need to be revised.
4. Tell and train employees if new hazards are introduced. See HazCom training.
5. Review controls: PPE, ventilation, storage and emergency procedures.

Tracking revisions in practice

Keep a log of every sheet with the supplier, product, revision date and the date you received it. Once or twice a year, check supplier websites for newer versions of the products you use most. Electronic SDS management systems can alert you automatically; with paper binders you need a recurring task. Link this to your chemical inventory review.

How old is too old?

No single age makes a sheet invalid under US rules, but a sheet that predates the 16-section format, or that is many years old for a product that has been reformulated, should be treated with suspicion. Compare it with the label: if the signal word or statements differ, ask the supplier which is current. For old documents titled MSDS, see SDS vs MSDS.

Worked scenario: a revised sheet arrives

Your cleaning supplier sends a revised sheet for a degreaser you use every week. The revision date in Section 16 is new, and the change summary says that Sections 2, 8 and 9 were updated. A sensible sequence is:

1. Open the old and new Section 2 side by side. Did the signal word, a pictogram or any hazard statement change?
2. Check Section 8. Did the recommended glove material or respirator change? If so, your PPE stock and your task instructions may need updating.
3. Check Section 9 for changes in flash point or pH, which can affect storage and compatibility.
4. Replace the sheet in your library, file the old one with the dates it was in use, and update the revision date in your inventory.
5. If the hazards changed, brief the people who use the product and update labels on workplace containers.

This takes minutes when you do it at once and becomes a real problem only when revised sheets pile up unread.

What auditors and inspectors tend to ask

• Is there a sheet for every product on the inventory, and is each one the current version you hold?
• Can you show the date each sheet was received?
• When a revised sheet arrived, what did you do with it?
• Do employees know where the sheets are, and did anyone tell them about the change?

A short written procedure for revised sheets, assigned to a named person, answers most of these questions.

Frequently asked questions