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New SDS Disclosures Require Changes to Overall Hazard Communication Policy

    Client Alerts
  • June 26, 2015

On June 1, new OSHA rules took effect for all employers, changing requirements for chemical manufacturers and importers who prepare and distribute Safety Data Sheets (SDS). Under these rules, the SDS (previously called Material Safety Data Sheets, or MSDS), must contain information on new categories of hazards presented through exposure of employees to those chemicals. Employers that receive the new SDSs should review their Hazard Communication programs to make certain that they take into account this new hazard information.


In addition to the SDS requirement, OSHA’s Hazard Communication standard requires labeling and training requirements. The new SDS requirements mandate use of the broader international GHS format that includes new categories of possible health effects resulting from chemical exposure. Employers that obtain this expanded information should review and where appropriate, amend their employee training, PPE, and exposure control measures to take into account this expanded hazard information.


OSHA has not yet issued a long-promised compliance directive aimed at advising compliance officers on how to apply the new SDS requirements to their workplace inspections. When published, this guidance should provide employers with some information regarding how OSHA will review Hazard Communication programs in light of the expanded hazard exposure requirements. As with most new OSHA rules, enforcement efforts will likely be gradual. By paying attention to employee training and other compliance requirements now, employers can prepare for any eventual enforcement proceedings based on their expanded obligations.