As an employer, compliance is always top-of-mind. Much of OSHA’s standards are very clearly defined and as such, very easy to follow. There are, however, a few gray areas regarding the update of SDSs when ‘significant information’ for a particular chemical has changed.
So, how do you know when it’s time to update your SDSs – and what constitutes a ‘significant’ change of information?
As a general rule, chemical suppliers are expected to periodically review, revise, and update their safety data sheets. Changes are made, as necessary, as new hazard info is found, new information about protective measures is ascertained, or changes are made to product information.
Though OSHA’s hazard communication standard does not clearly define what ‘significant information’ is, it is generally understood that it includes the change of classification, new hazards, new occupational exposure limits, new risk management measures and new protection methods against the hazard.
Here are three frequently asked questions regarding the update of SDSs to keep you compliant.
How often does OSHA require manufacturers/suppliers to update their SDS?
Under the Hazard Communication Standard (29 CFR 1910.1200), OSHA requires manufacturers and importers to obtain or develop SDSs for each hazardous chemical they produce or import. Manufacturers and importers must provide these SDSs to distributors and employers “ … at the time of the first shipment of the chemicals, and with the next shipment after the SDS is updated with new and significant information about the hazards.”
As for updating labels with new, ‘significant information,’ OSHA says, “Chemical manufacturers, importers, distributors, or employers who become newly aware of any significant information regarding the hazards of a chemical shall revise the labels for the chemical within six months of becoming aware of the new information, and shall ensure that labels on containers of hazardous chemicals shipped after that time contain the new information.”
When do manufacturers/suppliers have to update an SDS?
According to OSHA, “The chemical manufacturer, importer or employer preparing the safety data sheet shall ensure that the information provided accurately reflects the scientific evidence used in making the hazard classification. If the chemical manufacturer, importer or employer preparing the safety data sheet becomes newly aware of any significant information regarding the hazards of a chemical, or ways to protect against the hazards, this new information shall be added to the safety data sheet within three months.”
How often do end-users have to update their SDS?
If you are an end-user, it is your responsibility to use and keep the latest version – and ensure that it is easily accessed by all employees. You can simply ask the supplier or manufacturer to provide it.
A Compliance Partner That Works For You
At GSM, we are constantly communicating with manufacturers to ensure SDSs are always updated. We don’t wait for deadlines but have our own standard and sourcing process for compliance. As your compliance partner, you can rest assured knowing that we are making compliance a top priority so you can focus on your business. Schedule a free demo to see how GSM can help you today!