Do I need to have a safety data sheet (SDS) for commercial products like household window cleaner?

The answer depends. According to 29 CFR 1910.1200(b)(6)(ix), you are not required to have SDSs for any consumer product or hazardous substance, as those terms are defined in the Consumer Product Safety Act (15 U.S.C. 2051 et seq.) and Federal Hazardous Substances Act (15 U.S.C. 1261 et seq.) respectively, where you can show that:

• It is used in your workplace for the purpose intended by the chemical manufacturer or importer of the product, and
• The use results in a duration and frequency of exposure which is not greater than the range of exposures that could reasonably be experienced by consumers when used for the purpose intended.

You need to make a determination whether the product is exempted or not, based on the product itself, how your employees will use it, and the duration and frequency of use. Assuming the product is a consumer product used as intended, then:

• If employees will use the product with a duration and frequency as that of a normal consumer, then the use of the product does not require an SDS, nor does it fall under the Hazard Communication standard.
• If employees will use the product with a duration or frequency that exceeds that of a normal consumer, then the use of the product DOES require an SDS, and it falls under the Hazard Communication standard.

Employees who are required to work with hazardous chemicals in a manner that results 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, unless those chemicals are otherwise exempted under 1910.1200(b)(6). For more information, see OSHA Directive CPL 02-02-079 and look for the phrase consumer product.