Introduction
Safety data sheets are a fundamental part of both workplace safety and ongoing compliance. However, many organizations overlook the importance of keeping their SDS libraries current and accessible. Employers have an obligation to provide their employees with the correct SDS for any hazardous chemicals in the workplace, and there are real consequences if that obligation isn’t met. It puts workers at risk of serious injury and opens your business to penalties and other liabilities.
OSHA Requirements for SDS Management
OSHA lays out specific requirements for organizations to provide SDSs to their employees in its Hazard Communication Standard (HazCom). It requires an employer to have an SDS in the workplace for every hazardous chemical it uses, so organizations must align their SDS libraries with their current purchasing, inventory, and processes.
It also mandates that SDSs be readily accessible during every shift where employees are present in work areas. The standard does allow for electronic systems, but they must be sufficient to allow immediate access without barriers. Any complicated login processes, downtime during network outages, or restrictive permissions can pose compliance risks.
Having SDSs available is just one part of a required hazard communication program. Employers must have a written health and safety program that includes a hazardous chemical list that associates product identifiers with the corresponding SDSs. Workers must also receive the necessary training to locate, access, and understand these documents in accordance with their roles and specific tasks.
Employers must also label hazardous chemical containers in the workplace, showing a product identifier, relevant hazard statements and pictograms, and other details. Shipping containers must also include the name and telephone number of the manufacturer, importer, or other responsible party.
The Potential Cost of SDS Violations
Failure to comply with the HazCom standard poses the risk of OSHA violations and associated penalties. The amount of any specific penalty can vary depending on the classification and circumstances. Keep in mind that a single review or inspection can produce multiple separate citations involving SDSs, labels, written procedures, and training.
As of 2026, the maximum penalty per serious or other-than-serious violation is $16,550. Willful or repeated violations have a maximum of $165,514 each. Employers can also face failure-to-abate penalties of up to $16,550 per day for hazards that are still present beyond the abatement date. These maximums are per violation, meaning that individual cases involving multiple violations can greatly exceed these values.
Failure to Make SDSs Readily Available
A marine component manufacturer received a penalty of over $3,000 for violations at an Illinois facility in 2018. OSHA found that the employer stored SDSs on a company SharePoint site that was not readily accessible to employees during their shifts. Simply having documents stored somewhere online is not enough for compliance. Any digital SDS management system must remove obstacles rather than introducing barriers.
Missing Safety Data Sheets
A distribution and warehousing facility in Georgia received a citation for $2,450 in 2022 after OSHA found that they did not provide employees with access to SDSs for the specific hazardous chemicals present in the workplace. Specifically, they did not have SDSs on hand for detergents, corrosives, cleaning supplies, and propane. The requirement for SDSs is not limited to chemical process reagents or products, but also applies to any type of hazardous chemical in the workplace.
OSHA cited a tire retail and service facility in Texas with a penalty of over $7,000 in 2024. The employer lacked SDSs for a variety of products, including hydraulic fluid, sealants, oil, and cleaners. The need for SDS management extends across all types of businesses, facilities, and operations. Don’t risk penalties because you don’t consider your site to be a chemical facility.
Failure to Submit Chemical Inventory Reports
OSHA isn’t the only agency that issues penalties related to SDS management. Under the Emergency Planning and Community Right-to-Know Act (EPCRA), covered facilities must submit an annual Tier II chemical inventory report, including any new or revised SDSs, to state and local emergency planning and response organizations. In 2022, a chemical warehousing company in Connecticut faced $109,000 in penalties for combined EPCRA and CAA violations, including incomplete Tier II reports.
Costs Beyond Direct Penalties
OSHA and EPA fines are far from the only costs that can arise from poor SDS management. Inadequate access to SDSs in the workplace can impede responses to spills, fires, exposures, and medical emergencies. This puts employees at risk of injury and the ensuing liability for your company.
Property damage and operational disruptions are also risks here if employees don’t have ready access to the information they need to mitigate incidents. Poor response to spills and releases can worsen environmental incidents, potentially opening your organization up to further enforcement action by the EPA and other agencies.
Implementing an Effective SDS Management System
Your organization can take action to avoid these safety, operational, and compliance risks with the right SDS management system. You need a solution that lets you control supplier, in-house, current, and historical SDSs through a centralized platform. Any system must be readily accessible to employees in their actual work environment.
ERA’s SDS Management Software provides just such a solution. You can seamlessly manage all of your SDSs, with revision controls that maintain auditable records and ensure that your team always has the latest documents. Employees can view SDSs anywhere using ERA’s mobile app, with offline access to saved SDSs.
Don’t Overlook SDS Management and Expose Your Team to Risk
Maintaining compliance and keeping your team safe takes more than just having a collection of SDSs available somewhere. You must provide accessible, current documents when and where your team needs them. Implementing a system that meets these criteria lets you fulfill your obligations as an employer and avoid potential penalties. If you’d like to hear more about how ERA’s SDS Management Software can help you do that, schedule a call with ERA-EHS today.
Contributing Scientist of This Article:
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