In July 2024, the Occupational Safety and Health Administration (OSHA) published a final rule updating the Hazard Communication Standard (HCS) to align primarily with the seventh revision of the United Nations’ Globally Harmonized System of Classification and Labelling of Chemicals (GHS). These changes are designed to inform employees—including those in healthcare—about hazardous chemicals by making labels and Safety Data Sheets (SDSs) clearer and more consistent.
The updated standard for Safety Data Sheets aims to reduce chemical-related workplace illnesses and injuries by improving the information available to employees who work with hazardous chemicals. In healthcare settings, where chemicals are used for disinfection, sterilization, diagnostics, and research, this clarity is critical to maintain a safe workplace.
SDSs are a key part of the HCS. They help keep workers, patients, and the environment safe. The following sections explore OSHA’s SDS requirements and offer guidance on how healthcare organizations can maintain compliance.
What Is a Safety Data Sheet (SDS)?
A Safety Data Sheet is a document or file that provides essential information about a hazardous chemical – its properties, potential health and environmental risks, and instructions for safe handling, storage, and emergency response. OSHA requires that chemical manufacturers or importers supply SDSs to employers who use these chemicals. These documents are essential for understanding hazardous chemicals and maintaining workplace safety.
What is the Purpose of Safety Data Sheets?
A Safety Data Sheet (SDS) is your compass in the chemical landscape. Let’s break it down:
- Purpose: SDSs provide information on the hazards associated with chemicals. They guide safe handling practices and emergency procedures.
- Standardization: SDSs follow the Globally Harmonized System (GHS) criteria for classifying chemical hazards.
- Variability: The SDS format is standardized, but content may vary among manufacturers because it is product specific.
- Legal Requirements: Employers must obtain SDSs for all the hazardous chemicals they use, unless an exception applies, and make them readily accessible to employees.
- Training Responsibility: Employers must train employees on site-specific hazards of chemicals in the workplace along with how and where to access the SDSs.
What is Included in a Safety Data Sheet?
To ensure transparency and ease of use for those handling hazardous chemicals, OSHA requires each SDS to include certain sections covering essential topics, including:
- Chemical identification
- Hazard classification
- Safe handling and storage instructions
- First aid and firefighting measures
- Exposure controls and personal protection
- Toxicological information
The structure follows the GHS format, ensuring consistency across manufacturers and helping employees quickly locate the information they need in both routine and emergency situations.
Where Should Safety Data Sheets Be Stored or Accessed?
Employers, including healthcare organizations of all types, must provide employees with immediate access to SDSs applicable to the hazardous chemicals in their workplace. SDSs can be stored in various ways, such as:
- Paper copies in a binder
- Electronic files
- Offsite web-based services that can fax SDSs on request
If an organization chooses to store SDSs electronically or use the offsite web-based provider, it’s required to have a back-up available (e.g. paper or another electronic system) in case the computer or fax is not functioning. In addition, employees must be trained on how to access the SDSs on the computer as well as the backup system.
Do Employees Require Hazardous Chemicals Training?
Yes. OSHA requires that employees receive training before working with hazardous chemicals and again when new hazardous chemicals are introduced in the workplace if they have not been previously trained on that material. This training ensures staff understand the associated risks and know how to work with the substances safely.
Hazard chemical training should go beyond reading SDSs. Training should be clear, interactive, and connected to broader safety protocols. Organizations may group trainings by hazard category (such as carcinogens, acutely toxic agents, etc.) or incorporate SDSs content into larger OSHA-required safety programs – if all standards are met.
How to Ensure Your Organization Is Compliant with OSHA’s SDS Requirements
- Conduct a room-by-room inventory to identify all hazardous chemicals in use.
- Verify that an up-to-date SDS is accessible for each chemical. Assign someone to obtain missing SDSs.
- When an updated SDS is received, compare it to the previous version and promptly communicate any changes to relevant employees.
- Establish a centralized process for managing SDS updates and sharing revised hazard information to maintain compliance.
Many healthcare organizations choose to work with a third-party partner, like Stericycle, to assist with creating their SDS library, helping to streamline processes, improve access, and reduce compliance risks.
Stay Compliant With Confidence
Ensuring your organization meets OSHA’s SDS requirements is critical to protect staff, patients, and your facility as a whole. From maintaining up-to-date documentation to implementing effective training and access protocols, compliance demands a proactive, organized approach.
Learn more about how Stericycle can help you ensure compliance with OSHA’s Safety Data Sheet requirements.
