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 upon how the chemical is used in the workplace, and also how the chemical manufacturer intended the chemical to be used.

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 kitchen cleanser to clean the sink in the break room twice a week, that would be considered normal consumer exposure. However, if that employee cleans all of the sinks in all of the building’s bathrooms everyday, that would exceed normal consumer exposure, and the provisions of the hazard communication standard would apply.