Are Safety Data Sheets (SDS) Required for All Chemicals?

Determine whether a chemical is hazardous or nonhazardous.

When working with chemicals, safety must always be a priority. But not all chemicals are created equal and many require specific handling to avoid unnecessary accidents that expose workers to toxic hazards. That’s where Safety Data Sheets (SDS) come in.

Broadly speaking, all chemicals can be separated into two categories: hazardous and nonhazardous. While there is no definitive list of hazardous and nonhazardous chemicals, OSHA maintains a set of GHS-compliant standards to determine a chemical’s classification and thus determine whether or not a chemical needs an SDS. According to HazCom 2012, employers are required to have an SDS readily-accessible for all chemicals deemed hazardous.

Which Chemicals Are Considered Hazardous?

A hazardous chemical is one that poses a health hazard, a physical hazard, or an environmental hazard. While the definition itself is simple, the criteria is less so.
Health hazards are identified by how the body reacts when exposed to it. A chemical is a health hazard if exposure to it results in at least one of the reactions listed in Appendix A to 29 CFR 1910.1200 – Health Hazard Criteria:

  • Acute toxicity
  • Skin corrosion or irritation
  • Serious eye damage or eye irritation
  • Respiratory or skin sensitization
  • Germ cell mutagenicity
  • Carcinogenicity
  • Reproductive toxicity
  • Specific target organ toxicity (single or repeated exposure)
  • Aspiration hazard.

Physical hazards are identified by the physical properties and reactivity of the chemical itself. If a chemical has any of the properties listed in Appendix B to 29 CFR 1910.1200 – Physical Hazard Criteria, it is a physical hazard:

  • Explosive
  • flammable (gases, aerosols, liquids, or solids)
  • oxidizer (liquid, solid or gas)
  • self-reactive; pyrophoric (liquid or solid)
  • Self-heating
  • organic peroxide
  • corrosive to metal
  • gas under pressure
  • in contact with water emits flammable gas.

A chemical may also pose a health hazard if the classification criteria are not met, but the chemical still causes health effects such as slight irritation or nausea, but do not reach GHS classification criteria.

An environmentally hazardous chemical is one that has the potential to drastically and detrimentally disrupt the natural environment. GHS classification dictates that a chemical is an environmental hazard if it can cause damage specifically to either the aquatic environment (acute and chronic) or to the ozone layer.

Chemicals that meet any of the above criteria are hazardous and must have an accompanying SDS.

Learn more about the Hazard Communication Standard Pictogram here.

What If I Am Not Sure If a Chemical Is Hazardous?

If you have any doubts about whether a chemical is hazardous or nonhazardous, it is best to stick to the age-old adage of “better safe than sorry” and make an SDS because there can be serious consequences for not having an SDS for a hazardous chemical. For one thing, OSHA imposes hefty fines for noncompliance. More importantly, however, the absence of an SDS can lead to unnecessary exposures that leave your workers vulnerable to injury.

Caution is the name of the game when it comes to all things chemical. When in doubt, generate an SDS.


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