Safety Data Sheets or SDSs are only required for materials that meet OSHA’s definition of “hazardous”, meaning they are present in the workplace in such a manner that employees may be exposed under normal conditions of use or in a foreseeable emergency. SDSs are not required for household consumer products when used in the same manner as you would in the household. For example:
1. If the paint touchups you’re doing wouldn’t exceed a normal household use (and therefore, employees’ exposure to the paint isn’t above what would be considered normal in a household setting), you wouldn’t need an SDS. If it does exceed normal exposure in a household setting, then you do need an SDS.
2. If you are using bleach for disinfection in a clinical setting, employees’ exposure to bleach would most likely be considered greater than expected in a household setting and therefore, an SDS would be required.
When updating your SDS catalog, if the new datasheet contains the same hazardous chemical as the original formulation, then you can discard the superseded SDSs. If the formulation is different, then the employer either has to maintain both datasheets for at least 30 years or if you have some sort of record that identifies the substances used, where it was used, and when it was used, then you don’t need the superseded SDS. To be safe though, if you’re in doubt, we recommend keeping it on file (at least digitally). Check out this Letter of Interpretation from OSHA for more info.
At Gamma Compliance Solutions, we come to work every day because we want to solve the biggest problem in regulatory compliance: helping you make sure you have met all the requirements. Over the years, we have developed different compliance packages to suit practices at any stage in the OSHA and HIPAA compliance process. We have designated this area of our blog to post important updates and share key resources and guidelines you need to best protect your employees and yourselves. In addition to checking this area of our blog, follow us on social media to receive notifications when we share important information.