Guide
Who Must Provide an SDS?
Under OSHA's Hazard Communication Standard, the chemical manufacturer or importer must prepare an SDS for each hazardous chemical, distributors must give a copy to their customers, and employers must keep a copy for each hazardous chemical in the workplace and make it readily accessible to employees. Each link in the chain has a separate responsibility.
Last updated by SDS Lookup
Manufacturers and importers
Chemical manufacturers and importers must classify the hazards of what they produce or import and prepare a safety data sheet for each hazardous chemical. The sheet must be in English (they may add other languages) and follow the 16-section format. They must provide the sheet to downstream users with the initial shipment, and again with the first shipment after the sheet is updated. They are also responsible for keeping the sheet up to date; see SDS update requirements.
Importers cannot simply pass on a foreign sheet. They must make sure the classification and format meet US requirements. The same principle applies in other regimes, for example to importers and only representatives under EU REACH.
Distributors
Distributors must pass the manufacturer's or importer's sheet along to their customers. They must ensure that the sheet, and updated information, goes to other distributors and employers with the initial shipment and with the first shipment after the sheet is updated. Retail distributors that sell to employers have additional duties to provide sheets on request. A distributor that relabels or repackages a product takes on responsibilities that can be similar to a manufacturer's.
Employers
An employer who uses hazardous chemicals must keep an SDS for each one in the workplace, ensure employees can access it during their work shift, and train employees on how to use it. The employer must also maintain a written hazard communication program. If a sheet did not arrive with the shipment, the employer must obtain one from the chemical manufacturer or importer as soon as possible. See how to get an SDS and SDS binders and digital access.
Employers do not usually write SDSs, unless they also manufacture or blend chemicals. A company that blends its own mixtures from purchased chemicals and sells them is a manufacturer for HazCom purposes.
When does the sheet have to arrive?
The standard requires the sheet to be provided with the initial shipment, or earlier. It does not need to accompany every later shipment unless the sheet has changed. If a sheet is not provided, the employer should request it promptly rather than waiting for the product to run out. A product should not be used without a sheet if it is hazardous.
Other regimes
The details differ elsewhere. In Canada, suppliers must provide a bilingual SDS under WHMIS (see WHMIS). In the EU, REACH requires the supplier to provide an SDS free of charge, on paper or electronically, for substances and mixtures that meet the criteria (see EU REACH). In Great Britain, the equivalent is under UK REACH and GB CLP (see UK REACH and GB CLP).
Do consumers get an SDS?
Consumers buying household products usually rely on the label. A sheet is not usually enclosed, but many manufacturers post sheets online. For products used at work, even if sold at retail, the situation depends on the type of use. Read SDSs for consumer products for details.
Worked scenario: a distributor changes the brand
A facilities manager has bought the same degreaser for years. The distributor switches to a different brand with a similar name and does not send a new sheet. The old sheet in the binder no longer describes what is on the shelf. The manager should ask the distributor for the new manufacturer's sheet, check the label against it, and replace the old sheet. The distributor has an obligation to pass the manufacturer's sheet on to its customers, and the employer has an obligation to hold the right sheet for the product in use.
Whenever a product name, supplier or packaging changes, treat it as a possible new product and check the sheet.
What to keep as evidence
- The sheet itself, with the date you received it.
- Your written request, if you had to ask for it, and the reply.
- Any supplier statement that a product is not hazardous.
- Delivery documents that name the product, so you can show which sheet belongs to which delivery.
These records are cheap to keep and make audits much easier. They also support your chemical inventory.
Frequently asked questions
Who is responsible for providing an SDS to employers?
Chemical manufacturers and importers must prepare the SDS and give it to downstream customers, and distributors must pass it on. The employer's job is to keep it and make it accessible.
Do I have to pay for an SDS?
Suppliers are required to provide the SDS as part of the hazard communication duty. Many publish them free online.
What if my supplier will not send an SDS?
Request it in writing, keep a record of the request, and consider asking the manufacturer directly. If that fails, you can contact your local OSHA area office for help. See our guide on how to get an SDS.
Do small businesses need SDSs?
Yes. The standard applies to employers regardless of size when they use hazardous chemicals, although some small employers may have simpler programs.