01
Two rules, two clocks
The HazCom clock is "now." Under 29 CFR 1910.1200(g)(1) and (g)(8), employers must have an SDS for each hazardous chemical they use and keep it readily accessible to employees on every shift (the requirements guide covers access). This duty follows the chemical: while it's in the workplace, its current sheet is on file.
The records clock is thirty years. OSHA's rule on access to employee exposure and medical records, 29 CFR 1910.1020, covers records pertaining to employees exposed to toxic substances or harmful physical agents (§1910.1020(b)(1)), and it counts a safety data sheet indicating that a material may pose a hazard to human health as an employee exposure record (§1910.1020(c)(5)(iii)). Exposure records must be kept for at least 30 years (§1910.1020(d)(1)(ii)). That rule still says "material safety data sheets," the pre-2012 name; OSHA's HazCom inspection directive treats SDSs the same way, noting that older versions "may still need to be maintained" as exposure records.
The two clocks explain nearly every retention question. The current sheet is a HazCom duty; superseded sheets and sheets for chemicals that are gone can still be exposure records — and for any hazardous chemical your employees actually worked with, assume they are.
02
The 30-year rule, precisely
The records rule has a specific exception for safety data sheets, and it is the whole answer to "can I throw this away?" Sheets need not be kept for any specified period as long as some record of three things is kept for at least 30 years (§1910.1020(d)(1)(ii)(B)):
| Keep a record of | In practice |
|---|---|
| Identity | The substance or agent — the chemical name, if known. A trade name alone may not tell a doctor or investigator decades later what was in the drum. |
| Where it was used | The building, work area, or process. |
| When it was used | The date range the product was on site. |
So there are two lawful ways to comply: keep the sheets, or keep an identity-where-when record and discard them. A footnote to the same paragraph closes the obvious loophole: sheets must still be kept for chemicals currently in use, as HazCom requires. The exception only applies once a sheet is superseded or its chemical is gone.
Keeping the sheets is usually the easier option. An archived SDS already carries the identity, and your inventory history supplies where and when. Building a separate record means extracting chemical names from sheets you're about to throw away, which is more work than keeping them. The rule doesn't dictate a format: records may be preserved in any form as long as the information stays preserved and retrievable (§1910.1020(d)(2)). Scanned or electronic archives are fine.
03
Chemicals you no longer use — and the rest of the records rule
When a product leaves your site for good, its sheet moves from "current" to "archive." Take it off the inventory and out of the working library so nobody grabs it in an emergency, but don't delete it until the identity-where-when record exists. Write the end date down when the product leaves; reconstructing it years later is guesswork.
Three more provisions of the records rule attach to that archive:
- Employees can ask for it. When an employee or designated representative requests access to a record, the employer must provide it in a reasonable time, place, and manner; if that can't happen within 15 working days, the employer must explain the delay and give the earliest date it will be available (§1910.1020(e)(1)(i)).
- Employees must be told it exists. When employees start and at least annually after, they must be informed of the records, where they are, who maintains them, and their right to see them (§1910.1020(g)(1)).
- The archive outlives the business. An employer ceasing to do business must transfer the records to a successor employer. With no successor, current employees must be notified of their access rights at least three months before the business closes (§1910.1020(h)).
One scope note from OSHA's HazCom inspection directive: if a supplier sends an SDS for a material that isn't hazardous, the standard doesn't require you to keep it. Filing it costs nothing, though, and it answers the question if the classification ever changes.
04
When an SDS is missing
The standard puts the duty to supply sheets upstream. Manufacturers and importers must provide an SDS with the initial shipment and with the first shipment after it's updated, and provide one on request (§1910.1200(g)(6)(i), (iv)). Distributors must pass sheets along with the initial shipment and the first shipment after an update (§1910.1200(g)(7)(i)), and wholesale distributors must provide them on request (§1910.1200(g)(7)(vi)). Retail distributors with commercial accounts must provide sheets to those customers on request (§1910.1200(g)(7)(iii)). And when a labeled hazardous chemical arrives without its sheet, the employer must obtain one from the manufacturer or importer as soon as possible (§1910.1200(g)(6)(iii)).
The steps that work, in order:
- Check the supplier's website. Most manufacturers publish current sheets; download the one matching the product identifier and revision on your label.
- Request it in writing from the manufacturer, and from the distributor you bought it from. Keep the email.
- Follow up on a date. Put a reminder a week or two out; chase by phone and log the call.
- Escalate to OSHA if you're stonewalled. OSHA's 2015 inspection directive (now labeled an archive document) says an employer that has made a good-faith effort and still can't get a sheet may contact the OSHA Area Office, and that a letter or phone call from the Area Office to the supplier is the appropriate step.
- Decide about the product. The 2015 directive told officers to cite (g)(1) whenever an employer lacks an SDS, unless the employer can establish a good-faith effort to obtain it — "documented phone calls, email, letters." Without that record, the missing sheet is a citation waiting to happen. If a product can't be documented at all, taking it out of service until the sheet arrives is the conservative call.
The paper trail is the point. "We asked on March 3, followed up March 12, and escalated March 20" is a very different conversation with an inspector than "they never sent one."
05
When an SDS is out of date
Keeping sheets current is also an upstream duty: whoever prepares the sheet must add significant new hazard information within three months of learning it (§1910.1200(g)(5)), and ship the updated sheet with the next shipment (§1910.1200(g)(6)(i)). The 2015 directive spells out the downstream side: employers "assume no responsibility for the content and accuracy" of a supplier's SDS unless they change it; they must keep the most recent version received; and an employer holding an older sheet for a product it hasn't recently received was treated as compliant unless the supplier had sent a newer one that wasn't filed.
So "out of date" has three practical meanings, with three responses:
| The situation | What to do |
|---|---|
| A newer revision arrived | File it as the working copy right away, and move the old one to the archive — it's an exposure record now, not trash. |
| An MSDS-era sheet | A pre-2012 format sheet (not in the 16-section order of §1910.1200(g)(2)) for a product you still buy is a reason to request the current SDS — the supplier has had since 2015 to issue one. |
| Old, but still the latest | A sheet with an old Section 16 revision date isn't automatically out of date; some products don't change. Check the supplier's site for a newer revision. If there isn't one, you're keeping the most recent version, which is the duty. |
Through the 2024 update's transition, manufacturers, distributors, and employers may comply with the previous version of the standard (§1910.1200(j)(4)), so older sheets remain lawful for now; substance sheets were due to be updated by May 19, 2026, mixtures by November 19, 2027. The 2024 update guide covers what a revised sheet may mean for your site.
06
Don't fix a supplier's sheet yourself
It is tempting to correct a supplier sheet with an obvious error — a missing pictogram, a wrong phone number, a hazard you know is there. Don't edit their document. Employers aren't responsible for the accuracy of a sheet they didn't prepare, and the directive's wording ("unless the employer changes the SDS") suggests that editing it makes the content yours.
Do this instead. Notify the supplier in writing with the specific problem. Keep their sheet on file as received. And protect your people in the meantime: your own training, workplace labels, and procedures can reflect a hazard you know about even when the sheet doesn't. Your written program should describe this — what happens when a sheet seems wrong (the written program guide lists it among the SDS elements). Employers aren't required to classify chemicals themselves, but they may choose to (§1910.1200(d)(1)), and anyone who prepares a sheet takes on the preparer's duties.
07
The checklist
Walk this against your library and archive:
- Every chemical in use has its current SDS on file — the most recent version received.
- Superseded sheets are archived, not deleted — or an identity-where-when record replaces them, kept 30 years.
- Products that left the site have an end date recorded — and their sheets are out of the working library but in the archive.
- Missing sheets have a paper trail — dated requests, follow-ups, and escalation if needed.
- MSDS-era sheets for products still in use are requested as current SDSs.
- Suspect sheets are reported to the supplier — not edited in-house.
- Employees are told annually about the records, where they are, and their access rights.
- Access requests can be met promptly — for archived sheets as well as current ones.
- The archive has a succession plan — who receives it if the business is sold or closes.
The working half of that list is what SDS HQ's library is for: one searchable home for every current sheet, reachable on every shift through QR codes on containers, with a one-click binder PDF when you want a dated snapshot of everything on file. And the archive keeps itself: replace a supplier PDF with a newer revision and the old file stays under that sheet's previous versions; delete a sheet for a chemical that's gone and its file moves to Archived SDSs. Either way it's kept for 30 years, and sheets you author yourself keep every prior revision in version history.
NOTEThis guide is general information about the cited standards, not legal or professional advice for your facility. Regulatory text and agency enforcement practice control; confirm requirements against the standard and your competent person. Claims last reviewed October 13, 2026.