OSHA HazCom and SDS Requirements: What US Chemical Suppliers Need to Know
A plain-English summary of OSHA's Hazard Communication Standard (29 CFR 1910.1200) for Safety Data Sheets and labels: who must do what, the 16-section format, updates and training.
OSHA's Hazard Communication Standard (HazCom), 29 CFR 1910.1200, requires that the hazards of chemicals are classified and communicated to workers through labels, Safety Data Sheets and training. Since the 2012 revision, HazCom follows the GHS, which is why US SDS documents use the 16-section format.
This guide summarises the standard for suppliers. It is not legal advice, and you should read the current text of the standard on OSHA's website.
Who must do what
Chemical manufacturers and importers
They must classify the hazards of the chemicals they produce or import, prepare an SDS for each hazardous chemical, and make sure containers are labelled with the required elements. They must send the SDS to downstream users with the first shipment and again when it is updated.
Distributors
They must pass the SDS and labels on and may not obscure or remove the original hazard information. They must provide the SDS with the first shipment and when it changes.
Employers
They must keep an SDS for each hazardous chemical in the workplace, make them readily accessible to workers during every shift, maintain a written hazard communication program, keep workplace labels and train workers on the hazards.
The SDS format
HazCom specifies the 16 section headings in a fixed order. OSHA does not enforce the content of Sections 12 (ecological information), 13 (disposal), 14 (transport) and 15 (regulatory information) because they fall under other agencies' authority, but the headings must be present. See the 16 sections explained.
Updates
Chemical manufacturers and importers must update the SDS within three months of becoming aware of new significant information about the hazards of the chemical or ways to protect against them. Keeping a revision history makes this easier to demonstrate.
Recent changes
OSHA revised the standard again in 2024 to align it with a more recent revision of the GHS. The revision changes some classification criteria and label provisions and has phased compliance dates. Confirm the dates that apply to your products on OSHA's website before you plan the update.
Practical checklist
- Classify each product, including mixtures, under the current criteria.
- Generate the SDS and label from the same classification so they match.
- Send the SDS with the first shipment and after every material change.
- Keep revision dates and previous versions.
- Review when OSHA or another regulator changes the standard.
Frequently asked questions
- What does OSHA require on a Safety Data Sheet?
An SDS in the 16-section GHS format, with the content of Sections 1 to 11 and 16 enforced by OSHA, prepared by the chemical manufacturer or importer for each hazardous chemical.
- How soon must an SDS be updated?
Within three months of the manufacturer or importer becoming aware of new significant hazard information.
- Does HazCom apply to products I sell to consumers?
HazCom covers chemicals in the workplace. Consumer products have separate rules, although products also used at work may fall under HazCom.
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