Identifying materials exempted for SDS requirement by OSHA

According to OSHA, safety data sheets (SDS) are only required for hazardous chemicals. These chemicals pose a threat upon exposure to employees in a work environment. OSHA defines a hazardous substance as one which poses a physical or a health hazard, or both.

Employers are often confused as to whether they should have a SDS for a particular item or not. Since a material may be used in different forms, a data sheet may exist. But why waste your time trying to find a safety data sheet you don’t require?

Food and related items

Not all food and additives are exempt from Hazard Communication Standard. It is only exempted for those items which don’t possess a risk for employees handling them in downstream applications.
This includes alcoholic and non-alcoholic beverages for retail establishments and food intended for employees’ consumption in a workplace.
However, substances such as flour dust require an SDS.

Cosmetics

Packaged cosmetics for sale at retail establishments such as supermarkets and those meant for employee consumption don’t require SDS. However, beauty salons which are using these cosmetics ‘occupationally’ and manufacturing plants should have SDS.

Articles

All those items which are formed or designed in a particular shape and this design as whole or part, is responsible for function, will not require an SDS. However, these items must not pose risk to employees.
For instance, copper electrical wire rolls are distributed without SDS, but copper ingots for computer chip manufacturing must have SDS. These evaluations are mostly made on a case-to-case basis.

Pharmaceuticals

Drugs regulated by U.S. Food and Drug Administration (FDA) require SDS, except when in solid form (e.g. tablets) and prepared for direct administration to a patient. It also excludes packaged drugs for sale, for example, over-the-counter medicines.
However, manufacturing facilities and certain pharmacies require SDS for all drugs, including pills and tablets.

Consumer products

Only those products and chemicals are exempted which are used in their workplace, resulting in a time duration and exposure not greater than expected what’s from consumer intended purposes.
For example, use of cleaning products is exempted. However, the facility must show that exposure is not greater than intended purposes. If an employee is responsible for cleaning all day long and exposed to greater times, then SDS and proper training is required.
Ionizing and Non-ionizing Radiation

If these substances only pose a radiological hazard and no health or physical hazard are exempted.

Biological Hazards

Biohazards such as cell culture and microbes which do not possess a physical or health hazard are exempted from SDS. However, if the possibility of these hazards exist, then an SDS is required.

Office and School Supplies

Office workers who are not exposed to chemicals or any hazardous substances otherwise used in the organization, are not covered under these rules.

Certain office supplies, for example, printer cleaning solvents may pose a threat. Occasional use doesn’t require SDS and training. However, if a person is responsible for this and often use the hazardous substance, then they must be trained and informed.

Others:

Nuisance particulates and dusts, wood and lumber, hazardous wastes, tobacco and tobacco products are also exempted if they don’t pose a physical or health hazard.

Have you figured out which substances you need MSDS sheets for in your facility? Then search our online SDS database and add to the material safety data sheet binder.

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