Q: How long must I maintain old MSDS/SDS sheets? I’m thinking it is 30 years but want to be sure. I am interested in the federal requirements.

A: Each MSDS/SDS must be retained at the worksite for as long as the hazardous chemical is used at the worksite. The Occupational Safety and Health Administration (OSHA) does require retention of records on worker exposure to hazardous chemicals but does not specify retention of the MSDSs/SDSs with such records.

Current or former employees (or their designated representatives) may request and obtain from the employer MSDSs/SDSs for chemicals to which they may have been exposed. If the chemical is no longer used in the workplace, you are not required to maintain the MSDS/SDS with medical records. You must, however, maintain the chemical identity of the substance (if known) for at least 30 years and when and where in the facility it was used. Product inventories may serve this purpose.

Q: How long do we have to maintain an MSDS/SDS once the chemical is no longer used? It has not been identified in any employee exposure.

A: Each MSDS/SDS must be retained at the worksite for as long as the hazardous chemical is used at the worksite.

Be advised that a chemical that is deemed safe today may be reclassified as toxic (e.g., asbestos), and maintaining the MSDS/SDS is proof that your organization provided the most current information. It is certainly to your organization’s benefit to be able to produce documentation showing that you had supplied all the protective equipment and procedures necessary according to the MSDS/SDS you had at the time. See OSHA’s policy interpretation titled "Retention Requirements for Superseded MSDSs" for more information.

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Q: How many copies of my MSDS/SDS book do I have to have?

A: There is no OSHA requirement for multiple copies of MSDS/SDS binders as long as all employees have immediate access to the MSDS/SDS for the chemicals they work with or may be exposed to.

Q: Are companies required to update their MSDSs/SDSs every 2 years? If not, when?

A: You must update/replace the MSDS/SDS when the chemical manufacturer or distributor from whom you purchased the chemicals sends you an updated MSDS/SDS. There is no requirement to update them every 2 years.

For example, OSHA’s HazCom rule states that distributors must ensure that MSDSs/SDSs are provided with their initial shipment and with the first shipment after an MSDS/SDS is updated. Therefore, according to OSHA’s interpretation of its HazCom rule, the law "places the duty of providing updated MSDSs/SDSs on manufacturers, importers, and distributors" (OSHA interpretation letter dated April 18, 2008). "The user of the product, therefore, is in no way liable for the contents of an MSDS/SDS due to an alleged ‘lack of diligence’ on behalf of a distributor to update the data sheet" (OSHA interpretation letter dated February 7, 1997).

However, if you stopped purchasing the chemical and the MSDS/SDS was later updated by the manufacturer, the manufacturer probably will not send you the updated sheet until you repurchase the chemical. In such a case, it would be prudent (but not required) to periodically "audit" your chemical list in your written HazCom plan for chemicals that you no longer purchase and request MSDSs/SDSs for those chemicals from the manufacturer.

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