Do you need to keep SDSs for consumer products such as window cleaner?

OSHA does not require an employer to have safety data sheets (SDSs) for household consumer products when the products are used in the workplace in the same manner as a consumer would use them. In other words, when the duration and frequency of use, and therefore exposure, is not greater than what the typical consumer would experience.

This exemption is based, however, not upon the chemical manufacturer’s intended use of the product, but upon how it actually is used in the workplace. For instance, if an employee uses a cleanser to wipe down the table in the breakroom once a week, that would be considered normal consumer exposure. However, if an employee uses the chemical for custodial or janitorial purposes, that would exceed normal consumer exposure, and the provisions of the Hazard Communication Standard would apply.

Employees who are required to work with hazardous chemicals in a manner that result in a duration and frequency of exposure greater than what a normal consumer would experience have a right to know about the hazards of those chemicals. In those cases, the Hazard Communication Standard treats those consumer products as any other workplace chemical hazard.