01
The rule: every hazardous chemical you use
Two sentences in 29 CFR 1910.1200(g)(1) set the duty. Chemical manufacturers and importers must obtain or develop an SDS for each hazardous chemical they produce or import. Employers must have an SDS in the workplace for each hazardous chemical they use.
"Use" is broader than it sounds: the standard defines it as to package, handle, react, emit, extract, generate as a byproduct, or transfer (§1910.1200(c)). And the standard reaches any chemical known to be present in the workplace in a way that employees may be exposed under normal conditions of use or in a foreseeable emergency (§1910.1200(b)(2)). A drum nobody has opened in months still counts if a leak could expose someone.
02
What makes a chemical "hazardous"
A hazardous chemical is one classified as a physical hazard or a health hazard, a simple asphyxiant, combustible dust, or a hazard not otherwise classified (§1910.1200(c)). Health hazards are classified under Appendix A: acute toxicity, skin corrosion or irritation, serious eye damage or irritation, respiratory or skin sensitization, germ cell mutagenicity, carcinogenicity, reproductive toxicity, specific target organ toxicity, and aspiration. Physical hazards are classified under Appendix B, from flammable liquids and gases under pressure to oxidizers and chemicals corrosive to metal.
As a user, you don't have to do that classification. The manufacturer or importer classifies, and employers may rely on their classification (§1910.1200(d)(1)). The supplier's label is the visible result: a signal word, pictograms, and hazard statements mean the product is classified and an SDS is owed. If a shipment labeled as a hazardous chemical arrives without one, you must obtain it from the manufacturer or importer as soon as possible (§1910.1200(g)(6)(iii)).
The SDS duty covers hazardous chemicals only, so a supplier isn't required to provide an SDS for a product that isn't classified, though many do anyway. If you can't tell whether a product is classified, ask the supplier in writing and keep the answer.
03
The exemptions, and how narrow they are
Paragraph (b)(6) lists what the standard doesn't apply to at all. Nearly every entry carries a condition, and the condition is where sites go wrong:
| Exemption | The condition attached |
|---|---|
| Articles | A manufactured item, other than a fluid or particle, formed to a specific shape or design, whose function depends in whole or in part on that shape or design, and that under normal use releases no more than very small quantities of a hazardous chemical and poses no physical or health risk (§1910.1200(c)). Solid metal, wood, or plastic can lose article status because of its downstream use, such as cutting, grinding, or welding that releases dust or fumes; the standard has label rules for exactly those items (§1910.1200(f)(4)). |
| Consumer products | Exempt only when the employer can show it is used at work for the purpose the manufacturer intended, with exposure no greater in duration and frequency than a consumer's (§1910.1200(b)(6)(ix)). The dish soap in the break room qualifies. The same soap used all shift by a cleaning crew doesn't. |
| Wood and wood products | Exempt only when the only hazard is flammability or combustibility. Wood treated with a hazardous chemical, and wood that may later be sawed or cut and generate dust, are not exempt (§1910.1200(b)(6)(iv)). |
| Food, drugs, cosmetics | Food and alcoholic beverages sold, used, or prepared in a retail establishment, and food for employees' own consumption; drugs in solid, final form for direct administration to a patient (tablets, pills), drugs packaged for retail sale, and drugs for employees' own use such as first-aid supplies; cosmetics packaged for retail sale or for employees' own use (§1910.1200(b)(6)(vi)–(viii)). |
| Hazardous waste | Hazardous waste when it is subject to EPA regulations under RCRA, and CERCLA hazardous substances when they are the focus of a remedial or removal action (§1910.1200(b)(6)(i)–(ii)). |
| The rest | Tobacco and tobacco products; nuisance particulates the manufacturer or importer can show pose no hazard covered by the standard; ionizing and nonionizing radiation; biological hazards (§1910.1200(b)(6)(iii), (x)–(xii)). |
When a product fits an exemption only some of the time, such as the consumer product used heavily or the wood that sometimes gets cut, keep the SDS. An extra sheet in the library costs nothing. A missing one can be a citation.
04
Exempt from labeling is not exempt from the SDS
A separate list, §1910.1200(b)(5), covers products whose labels are governed by another federal law: pesticides under FIFRA, chemicals labeled under TSCA, foods, drugs, cosmetics, and medical or veterinary devices under the Food, Drug, and Cosmetic Act, beverage alcohol, consumer products under the Consumer Product Safety Commission's laws, and pesticide-treated seed.
Those products are exempt from HazCom's labeling requirements only — the paragraph says the standard "does not require labeling" of them. The SDS, the written program, and training still apply. A pesticide in the grounds crew's shed needs its SDS on file even though its label follows EPA's rules instead of OSHA's. Some of these product types also appear in the (b)(6) exemptions above, but only under those narrower conditions.
05
Labs, warehouses, and sealed containers
Two settings get a lighter version of the rule. In laboratories, employers must keep the SDSs that arrive with incoming shipments, keep them readily accessible to lab employees during each shift, leave incoming labels intact, and train employees (§1910.1200(b)(3)). A lab that ships hazardous chemicals out is treated as a manufacturer or distributor for those shipments.
Where employees handle chemicals only in sealed containers that aren't opened under normal use, as in warehousing, retail sales, or marine cargo handling, employers must keep the SDSs that arrive with shipments, obtain one as soon as possible for a sealed container that arrived without one if an employee asks for it, keep them accessible, and train employees to the extent needed to protect them in a spill or leak (§1910.1200(b)(4)). If the work involves opening those containers, the limited rule no longer fits and the full standard applies.
06
Sorting the shelf: a walk-through
- Walk every area with a list, storage rooms and vehicles included, not just the production floor.
- Read each label. "Danger" or "Warning" with GHS pictograms and hazard statements means the product is classified. It needs an SDS unless an exemption applies.
- Check every product against the exemptions, labeled or not. A consumer product used the way a consumer would use it is exempt even if its label carries a signal word such as "Caution" or "Warning". Write down which exemption applies and why.
- Not sure? Ask the supplier whether the product is classified, and keep their answer with your records.
- Give every hazardous chemical a current SDS, and put it on the written program's chemical list under the same product identifier the sheet uses (§1910.1200(e)(1)(i)).
The list you build here is the core of your written hazard communication program, and the 16-section guide covers what to check on each sheet you collect.
Once you know which sheets you need, SDS HQ's library keeps them in one place: upload supplier PDFs one at a time or in bulk, and the product name, supplier, and hazard codes are read off each sheet as it comes in. The Free plan holds up to 200 SDSs.
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.