How to Create an SDS Index Template: Retention, Backups, and Penalties

An SDS index template is the master list of every hazardous chemical present at your workplace, formatted so any employee can find the matching Safety Data Sheet during any shift. OSHA’s Hazard Communication Standard requires this list as part of your written hazard communication program, and each chemical on it must be identified by the same product name printed on its SDS.¹ You can build one list for the whole site or separate lists by work area. Either way, it has to be written down, it has to be current, and employees have to be able to reach it without waiting.

What Belongs on Each Line

Every entry pulls from information already printed on the chemical’s SDS, mostly from Section 1 (Identification) and Section 16 (Other Information). At minimum, each row needs:

Product identifier, spelled exactly as it appears on the SDS and the container label. Small mismatches between the index and the label cause real confusion during emergencies.
Manufacturer or supplier name, which tells you who to contact when a formulation changes.
Emergency contact number from Section 1 of the SDS.²
SDS revision date from Section 16, so you can tell at a glance whether the sheet on file is current.²
Signal word from Section 2, either “Danger” or “Warning,” so employees can gauge severity without opening the full sheet.
Storage location. Not required by the standard, but one of the most useful fields you can add.

Larger facilities often add internal tracking numbers, department codes, or quantity estimates. Those help with procurement and auditing. The nonnegotiable rule is that the product identifier on your index has to match the identifier on the SDS, because that is what the regulation names as the link between the chemical list and the safety information.¹

How to Organize It

OSHA does not specify a format, which leaves you free to match how your workplace actually operates. Common approaches:

Alphabetical by product name. Simplest, most intuitive, works well below roughly a hundred chemicals.
By department or work area. Employees see only the chemicals they might touch. Useful in manufacturing plants and hospitals where different wings handle very different substances.
By manufacturer. Makes batch-requesting updated SDSs easier for procurement.
By hazard category. Flammables together, corrosives together. Handy for emergency planning, less intuitive for a daily lookup.

Most sites end up combining methods. A spreadsheet sorted alphabetically with filterable columns for department, hazard class, and manufacturer covers most needs. The regulation allows one list for the entire workplace or separate lists per work area, so pick whichever version employees will actually use.¹

Keeping It Current

An index that no longer matches the shelves creates false confidence. Three trigger points:

A new chemical arrives. Add its entry before employees begin using it, and check the fields against Section 1 and Section 16 of the SDS shipped with the product.
A chemical leaves the site. Move the entry to an archive rather than deleting it. The retention rules below mean you may need that record for decades.
The manufacturer issues a revised SDS. Update the revision date, swap the old sheet, and note any change to the signal word or hazard classification.

Schedule periodic audits where somebody walks the storage areas and compares the shelves to the list. Quarterly works for most facilities. Monthly makes sense in high-turnover environments like labs. Log each audit date; that log is what shows an inspector you are running the program rather than filing it.

The 30-Year Retention Rule

This is where employers get caught off guard. A separate OSHA regulation, 29 CFR 1910.1020, treats a chemical inventory as an “employee exposure record” when it reveals the identity of a toxic substance or harmful physical agent along with where and when it was used.³ Employee exposure records have to be preserved for at least 30 years.⁴

You do not necessarily have to keep every superseded SDS for three decades. The regulation offers a trade: you can discard the old SDS as long as you keep a simplified record of the chemical name, where it was used, and when it was used, and hold that record for at least 30 years.⁴ Your index, if it carries those three data points, can serve as that record. That is the practical reason to add storage location and date-range-of-use columns to your template even though the Hazard Communication Standard does not demand them.

Digital Systems and Backups

OSHA allows electronic SDS systems as long as employees can pull up the information immediately at their work stations. “Readily accessible” means immediate, and OSHA has stated that electronic-only setups need a plan for power outages and network failures.⁵

Acceptable backups include an auxiliary power system, a phone-based service that can read hazard information aloud in an emergency and deliver a physical copy to the site as soon as possible after, or a printed binder alongside the digital system. When the primary system fails, the delay allowed is the shortest time possible to get a physical copy to the employee. A power outage that leaves workers hours from any chemical data is a compliance failure. A printed binder with tabbed dividers in each work area is the most foolproof backup.

Contractors and Non-English-Speaking Workers

If outside workers set foot on your site, such as construction contractors, maintenance vendors, or staffing agency employees, your written program has to describe how you will give those employers access to SDSs for chemicals their workers might encounter.⁶ Practically, your index and the SDSs cannot sit behind badge-access systems those workers cannot reach. Many host employers hand contractors a printed copy of the relevant portion of the index during orientation, along with the SDSs for chemicals in the work area.

Language is the other accessibility issue. SDS information must be in English, though it may also be provided in other languages.² Where employees do not read English fluently, that minimum often will not carry an inspection. Bilingual column headers, hazard pictograms alongside text entries, or bilingual supervisors on shift are all ways to close the gap. The regulation does not require a translated index. An inspector will look at whether your employees can actually use the system you have.

What It Costs to Get This Wrong

A missing or incomplete SDS list is one of OSHA’s most frequently cited violations. As of 2025, a serious violation carries a maximum penalty of $16,550, and willful or repeated violations can reach $165,514 per violation.⁷ These figures adjust annually for inflation.⁸

Penalties are assessed per violation, not per inspection. If an inspector finds three departments without accessible SDSs, that can be three separate citations. A missing or incomplete chemical list is also a separate violation from missing SDSs, so a neglected index compounds quickly. A clean, current list that matches the shelves and is reachable from every work area on every shift is the cheapest form of insurance against those numbers.

1
eCFR. 29 CFR 1910.1200 – Hazard Communication
2
Occupational Safety and Health Administration. Hazard Communication Standard: Safety Data Sheets
3
Occupational Safety and Health Administration. Access to Employee Exposure and Medical Records
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eCFR. 29 CFR 1910.1020 – Access to Employee Exposure and Medical Records
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Occupational Safety and Health Administration. Clarification of Systems for Electronic Access to MSDSs
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Occupational Safety and Health Administration. 29 CFR 1910.1200 – Hazard Communication
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Occupational Safety and Health Administration. US Department of Labor Announces Adjusted OSHA Civil Penalty Amounts for 2025
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Occupational Safety and Health Administration. OSHA Penalties