Do I need to keep Safety Data Sheets for 30 years?
In absolute terms, no. OSHA’s Hazard Communication (HazCom) standards don't require companies to retain Safety Data Sheets (SDS) for any minimum duration of time. But that 30 year figure doesn't come out of nowhere. So, let's look at where it came from and what you should really do with your Safety Data Sheets.
(To learn more about SDS and HazCom, see Making Sense of Hazard Communication)
Where Did the 30 Year Claim Come From?
If I were to wager a guess, the 30 year thing comes from the fact that OSHA requires employers to keep employee medical and exposure records for the duration of their 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 employee's exposure records.
Some people have interpreted this blurb to mean that all Safety Data Sheets must be retained for 30 years, no matter what the situation. And unfortunately, the misinterpretation of the standard has been passed along and the confusion has carried over well into the new millennium.
When to Get Rid of an SDS
OSHA requires establishments to maintain an SDS for each hazardous chemical they use or have on site. If a chemical stops being used, then the SDS for that chemical can be discarded.
Discarding outdated Safety Data Sheets is optional, but it is a good practice. All SDS must be reviewed, maintained, and kept in a manner that ensures easy access by employees. Eliminating all unnecessary SDS makes it easier for workers to find the one they need and makes managing the database more efficient.
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. Holding on to an excess 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.
(Learn more in Everything You Need to Know About Safety Data Sheets)
When You Should Preserve an SDS That Is No Longer in Use
As mentioned above, there is one major exception. An SDS might be included in an employee's 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
- First aid records
Like workers compensation case files, these records can be hundreds and sometimes thousands of pages long. By comparison, sorting through Safety Data Sheets is a delight.
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 it may not ultimately be necessary. The info found in an SDS, while useful, may not have the breadth and depth of the medical and exposure data that will 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 until it’s superseded by more comprehensive data) is a prudent course of action.
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