Do I need to keep Safety Data Sheets for 30 years?
In absolute terms, no. OSHA’s Hazard Communication (HazCom) standards do not require that companies retain Safety Data Sheets (SDS) for a minimum duration of time. But, there may be a reason why so many people believe otherwise (to learn more about SDS, see Making Sense of Hazard Communication).
OSHA requires that employee medical and exposure records be retained for the duration of employment plus 30 years. In the event of a chemical exposure, a Safety Data Sheet is a useful source of information. In fact, OSHA uses SDS as an example of data that could be considered part of an exposure record. Some people interpreted this blurb to mean that all SDS must be retained for 30 years. And, as sometimes happens, a misinterpreted standard was passed along and confusion has persisted well into the new millennium.
(OSHA’s HazCom set of standards is found in 29 CFR 1910 Subpart Z [Toxic and Hazardous Substances], beginning at 1910.1200.)
When to Get Rid of an SDS
OSHA requires establishments to maintain "a safety data sheet in the workplace for each hazardous chemical which they use." If a chemical is no longer used in the workplace, then the SDS for that chemical can be eliminated. All SDS must be reviewed, maintained in a manner that ensures immediate employee access, and updated when necessary; it’s in the best interest of efficiency to minimize this burden.
For each chemical (and SDS), there also must be "a list of the hazardous chemicals known to be present." The chemical list is a component in a written HazCom program. A greater number of SDS means more time is required to keep the chemical list up to date. Retaining SDS for chemicals no longer in the workplace, then, costs money that doesn’t need to be spent.
When You Should Preserve an SDS That Is No Longer in Use
As mentioned above, an SDS can be included in an employee medical record. A medical record could include all sorts of data, such as medical and employment questionnaires; employee medical complaints; examination results; medical opinions, recommendations, and diagnoses; progress and treatment descriptions; and first aid records. Like workers compensation case files, these records can be hundreds and sometimes thousands of pages long. By comparison, Safety Data Sheets are delightful.
(OSHA’s Employee Exposure and Medical Records set of standards is also found in 29 CFR 1910 Subpart Z, beginning at 1910.1020.)
Exposure records contain information such as environmental monitoring or measuring (e.g. sampling techniques and analytical methodologies), biological monitoring results (e.g. the level of a chemical in the blood, urine, or breath), and Safety Data Sheets (if they sufficiently identify the substance involved and the nature of the human health hazards).
An SDS can present important information about a chemical involved in an exposure, but its treatment as an employee exposure record may not ultimately be necessary. The info found in an SDS, while useful, may be nowhere near the breadth and depth of the medical and exposure data that’ll be forthcoming (and required to be kept for the duration of employment plus 30 years). But, at the beginning of the exposure documentation endeavor, retaining the SDS, at least temporarily until it’s superseded by more comprehensive data, would be a prudent course of action.
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