OSHA Changes to Safety Data Sheets (SDS) in the Past Year: In-Depth Overview and Timeline

In the past year, OSHA has issued a series of important clarifications and updates to the regulations governing Safety Data Sheets (SDS) to ensure better hazard communication in the workplace. These updates primarily focus on improving the clarity of health hazard information, transport and disposal guidelines, and language accessibility, as well as refining the application of SDS regulations for different substances and mixtures.

This post will provide an in-depth look at the key changes to OSHA's SDS requirements over the past year, their implications, and a detailed timeline for compliance based on substances and mixtures.

Key OSHA Changes to Safety Data Sheets in 2024

1. Clarified Hazard Communication Requirements for SDS

In 2024, OSHA issued clarifications around how imported chemicals and mixtures should be classified and labeled under the Hazard Communication Standard (HCS). This addressed discrepancies and ambiguities between different international chemical classification systems and OSHA’s standards. The clarification ensures that substances and mixtures are classified in accordance with GHS criteria, and that all SDSs reflect these classifications clearly and consistently.

Key Changes Include:

  • Updated hazard classifications: SDSs must provide clear classifications of both physical and health hazards. For example, a substance may have been previously categorized as "harmful," but now might be classified as "toxic" based on more recent scientific data.
  • Labeling of imported chemicals: If chemicals are imported from other countries that use different standards, they must still meet OSHA’s criteria for classification, SDS format, and hazard labeling.

2. Expanded Toxicological Data and Health Hazard Information

OSHA’s revisions to the SDS guidelines in 2024 require more comprehensive toxicological data. For example, chemicals that are classified as carcinogenic or toxic to reproduction must now provide detailed health risk information, including:

  • Specific health hazards: SDSs must explicitly describe the chemical’s potential for long-term health effects, including carcinogenicity, reproductive toxicity, and organ-specific damage.
  • Carcinogenicity details: The updated guidelines require more comprehensive data on whether a chemical is classified as a carcinogen by authoritative bodies like the International Agency for Research on Cancer (IARC) or the U.S. National Toxicology Program (NTP). If a substance is classified as a carcinogen or potential carcinogen, it must be clearly indicated in the SDS.

3. SDS Format Updates

While the 16-section SDS format remains in place, OSHA made additional clarifications about specific sections:

  • Section 3 (Composition/Information on Ingredients): SDSs must include specific concentration ranges for each hazardous ingredient. For trade secret chemicals, employers must ensure that trade secret claims are substantiated and comply with GHS classification guidelines.
  • Section 14 (Transport Information): Updated guidance clarifies that chemicals classified for transport must include the appropriate UN number, transport hazard class, and the proper shipping name. This section ensures compliance with both DOT and international regulations.
  • Section 15 (Regulatory Information): The regulatory information section now includes clearer guidance on ensuring that SDSs contain the necessary references to all relevant regulations, including specific OSHA standards, state laws, and EPA rules.

4. Language Accessibility

OSHA's 2024 clarifications also emphasize the need for SDSs to be accessible in the language(s) spoken by workers. This addresses the growing need for workplaces with multilingual employees to ensure that SDSs are comprehensible to all workers. If the workforce speaks more than one language, employers may need to provide SDSs in multiple languages or offer additional tools (like bilingual safety personnel) to facilitate communication.

Timeline for Compliance Based on Substance and Mixtures

Understanding the timeline for compliance is essential to ensure that your SDSs meet OSHA’s updated requirements. While some changes are immediate, others are rolled out over time depending on the type of chemical (substance vs. mixture) and its classification.

Here’s a breakdown of the timeline for full compliance, particularly focusing on when SDS updates must be rolled out for different substances and mixtures:

Immediate Compliance Requirements (2024)

  • Health Hazard Updates: As of 2024, all SDSs must reflect updated toxicological information, including details about carcinogenicity, reproductive toxicity, and organ toxicity, regardless of whether the chemical is a substance or a mixture.
  • Language Accessibility: Employers must immediately ensure that SDSs are accessible in languages spoken by their workers. This should be done when new chemicals are introduced to the workplace or when SDSs are updated.
  • Updated Transport Information: The latest clarifications regarding transport and disposal information must be included in all new and updated SDSs, regardless of whether they are substances or mixtures.

Roll-Out Schedule for SDS Updates by Substance and Mixture

The timeline for compliance with the updated SDS requirements is primarily determined by whether the chemical is a substance or a mixture, as well as its hazard classification.

  1. Substances (Individual Chemicals)

For substances, the changes to SDSs and classification must be fully implemented in 2024. This includes:

  • Ensuring that the updated hazard classifications (e.g., carcinogenicity, reproductive toxicity) are reflected on the SDS.
  • Updating the health hazard information based on recent toxicological studies or classifications by authoritative bodies.
  • Ensuring that the transport, disposal, and regulatory information is compliant with both OSHA and DOT standards.

By 2024, all SDSs for individual substances should already have been revised to reflect these requirements.

  1. Mixtures (Chemicals Composed of Multiple Substances)

The timeline for mixtures is slightly different, as these often require more complex hazard classification due to the different properties of the constituent chemicals. Here’s the roll-out schedule for SDS updates specific to mixtures:

  • 2024-2025: SDSs for mixtures that are newly introduced to the market, or those that have been newly classified based on updated hazard data, must comply with the updated hazard classifications. This means that mixtures with newly identified hazards (e.g., reproductive toxicity or carcinogenicity) must have SDSs updated by 2025 to reflect these new data.
  • 2025-2026: Existing SDSs for mixtures should be updated to reflect the most current GHS classifications and hazard data. This includes reviewing toxicological information and updating the SDS for any mixtures whose hazard status has changed based on new scientific information or regulatory updates. This final phase of updates will be fully enforced by 2026.

Final Compliance Deadline (2026)

  • 2026 will be the ultimate deadline for full compliance across all substances and mixtures, with every chemical in the workplace (whether a substance or mixture) needing to meet all updated requirements in terms of health hazard information, classification, labeling, and accessibility.

What Employers Should Do Now

  1. Review and Update SDSs: Conduct an audit of your current SDS inventory, ensuring that all new hazard information (including carcinogenicity and other long-term health effects) is included. Update any SDSs that are not compliant with the latest OSHA standards, paying particular attention to substances and mixtures introduced after 2024.
  2. Ensure Labeling and Transport Information Compliance: Double-check that SDSs reflect the most current transport and disposal guidelines. This includes UN numbers, hazard classes, and compliance with DOT and international transportation standards.
  3. Provide Ongoing Training: Make sure employees are trained on how to read and interpret the new SDS format. Special attention should be given to understanding new health hazard information and recognizing key hazard symbols and statements.
  4. Ensure Language Accessibility: If you have a multilingual workforce, ensure that SDSs are available in all required languages. Provide training to ensure that workers fully understand the safety data related to hazardous chemicals.
  5. Stay Updated: Regularly check for any new OSHA guidance or changes to GHS requirements, especially as they relate to mixtures and complex chemicals. Staying proactive will help you avoid non-compliance and ensure a safer working environment.

Conclusion

OSHA's updates to SDS requirements in 2024 are designed to improve the safety and accessibility of critical chemical hazard information for workers. With a clear timeline based on substances and mixtures, employers have a roadmap to follow in order to ensure compliance.

Please contact us for questions regarding these requirements or regarding our SDS Authoring Services.