How long do we need to keep obsolete SDSs?

Under 1910.1200, “Hazard Communication,” an employer does not have to keep SDSs once the materials are no longer in the facility and employees could no longer be exposed. In fact, OSHA wants you to get rid of obsolete SDSs so that employees are not hampered by looking through obsolete material in an emergency.

However, if employers are using SDSs to comply with 1910.1020, “Access to Employee Exposure and Medical Records,” then they need to be kept for the life of the exposed employee’s employment, plus thirty years, according to the exposure records requirements in 1910.1020(d)(1)(ii). Specifically, the regulation states, “Each employee exposure record shall be preserved and maintained for at least thirty (30) years, except that ... (d)(1)(ii)(B) safety data sheets and paragraph (c)(5)(iv) records concerning the identity of a substance or agent need not be retained for any specified period as long as some record of the identity (chemical name if known) of the substance or agent, where it was used, and when it was used is retained for at least thirty (30) years ...” Employers do not need to keep SDSs as exposures records. However, if the facility uses SDSs as part of the exposure records, employers must retain them somewhere for thirty years. They shouldn’t be kept with active SDSs, however.