A client called us last month with a question that sounded simple: “Can we go paperless on our Safety Data Sheets?” The answer was yes — but with some conditions that caught them off guard. That conversation turned into a full review of their SDS program and uncovered gaps that a CUPA inspector would have flagged immediately.
If you manage hazardous chemicals at your facility, your SDS program deserves a closer look. Here are the questions we hear most often — and the answers that matter.
Can We Go Digital? Yes, But Remove the Barriers
Cal/OSHA and federal OSHA both require that Safety Data Sheets be readily accessible during each work shift to employees in their work areas (29 CFR 1910.1200(g)(8)). The standard permits electronic access, but only if there are no barriers to immediate employee access.
That means your SDS library cannot sit behind a login screen employees don’t have access to. It can’t require a supervisor’s permission. It can’t be on an HR platform that only managers can reach.
What does work:
- QR code posters throughout the facility that any employee can scan with a personal phone
- Dedicated tablet stations in each work area loaded with your SDS library
- A centralized computer terminal that employees can walk up to and use without logging in
One thing many facilities overlook: you need a backup plan for power outages. OSHA letters of interpretation confirm that a phone number employees can call to request hazard information qualifies as a backup, as does a backup generator system. Even so, we recommend keeping one physical binder in a central, accessible location as a failsafe. In an emergency, a paper binder is more reliable than trying to get a tablet out the door.
How Long Do We Have to Keep Old Safety Data Sheets?
This is where employers are often surprised. Under OSHA’s Access to Employee Exposure and Medical Records standard (29 CFR 1910.1020), chemical exposure records must be retained for 30 years. Employers have two options: retain copies of the actual SDS documents, or maintain alternative records that identify the chemical name, where it was used, and when it was used. In practice, retaining the SDS documents themselves is by far the simplest compliance path — and it’s what we recommend.
A few details that trip people up:
- SDS records must be manufacturer-specific and formulation-specific. If you buy the same product from two different manufacturers, keep both versions. If a manufacturer changes the formulation, keep both the old and the new.
- You can archive the outdated version and only display the current one for employees — but the archived copies must be retrievable.
- This requirement survives a change in ownership. If your business is sold, those archived Safety Data Sheets must transfer to the new employer or be sent to the Director of NIOSH. If the business closes, the same rule applies.
When Can You Throw Out an Old SDS?
Only when a new version has been issued and the formulation and hazard information are identical — same chemicals, same hazards, no changes. If anything changed, keep both.
Our recommendation: never discard old SDS documents. Storage costs for electronic files are negligible, and a complete historical archive provides a strong defense if an employee health claim arises years later. A company that can show it relied on the most current SDS available when it set up its engineering controls is in a far stronger position than one that tossed its records.
How CDMS Can Help
CDMS regularly reviews SDS programs as part of our Comprehensive Safety Compliance Management services. We can evaluate whether your current system meets accessibility requirements, help you transition to a digital SDS platform that satisfies OSHA’s “no barriers” standard, and set up a retention and archiving process that keeps you compliant without creating busywork.
Get a Free SDS Program Assessment
Not sure where your SDS program stands? We’ll review your current setup, identify gaps, and give you a clear path forward.
Request Your Free Assessment or reach out to service@cdms.com.
CDMS provides comprehensive environmental and safety compliance management to manufacturing and industrial facilities across California. Our safety compliance services include Hazard Communication programs, compliance audits, and employee training.
