OSHA changed MSDS to SDS on March 26, 2012, when it published a final rule revising the Hazard Communication Standard to align with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The rule took effect May 25, 2012, with a phased compliance schedule that ran through June 1, 2016. A second update published May 20, 2024, tightened the standard again, and some of those compliance deadlines extend into 2026.1Occupational Safety and Health Administration. Hazard Communication – 2012 Standard
The 2012 Rule That Retired the MSDS
Before 2012, chemical manufacturers designed their own Material Safety Data Sheets however they liked. There was no required section order, no uniform headings, and no standard set of hazard symbols. Two sheets for the same chemical could look nothing alike. OSHA proposed aligning the Hazard Communication Standard with the United Nations’ GHS on September 30, 2009, and published the final rule on March 26, 2012.1Occupational Safety and Health Administration. Hazard Communication – 2012 Standard That rule formally retired the term “Material Safety Data Sheet” from federal regulation and replaced it with “Safety Data Sheet.”
The rule set a phased schedule so the whole supply chain wasn’t expected to switch on the same day:
- Chemical manufacturers and importers had until June 1, 2015 to reclassify their chemicals under GHS criteria and produce compliant Safety Data Sheets.
- Distributors had until December 1, 2015 to ship products with updated GHS-compliant labels.
- Employers had until June 1, 2016 to update workplace labeling, revise their written hazard communication programs, and retrain employees on the new SDS format and label elements.
By mid-2016 the transition was complete across the supply chain. Any workplace still relying on old-format MSDS documents after that date was out of compliance.1Occupational Safety and Health Administration. Hazard Communication – 2012 Standard
The 2024 Update and the 2026 Deadlines
OSHA published a second major revision to the Hazard Communication Standard on May 20, 2024, bringing the U.S. into alignment with GHS Revision 7.2Occupational Safety and Health Administration. Hazard Communication Standard – Final Rule The basic 16-section SDS format didn’t change. The update added new hazard classes, refined classification criteria, and updated label requirements. The current regulation states explicitly that it is intended to be consistent with GHS Revision 7.3eCFR. 29 CFR 1910.1200 – Hazard Communication
OSHA originally set compliance deadlines beginning in January 2026, then extended all dates by four months. Chemical manufacturers, importers, and distributors now have until May 19, 2026, to evaluate and reclassify certain substances under the updated criteria. During the extension period, businesses can comply with either the previous or updated version of the standard.4Occupational Safety and Health Administration. HCS 2024 Compliance Date Extension Notice
What Actually Changed on the Page
The most visible change is structure. Old MSDS documents had no required format. Some ran four pages, some twenty. The SDS replaced that with a mandatory 16-section format that every chemical manufacturer follows in the same order.3eCFR. 29 CFR 1910.1200 – Hazard Communication
The consistent numbering is the practical win. First-aid information is always Section 4. Recommended personal protective equipment is always Section 8. Physical and chemical properties are always Section 9. The first eleven sections are mandatory under OSHA. Sections 12 through 15 (ecological information, disposal, transport, and regulatory information) are required by the GHS format but fall outside OSHA’s jurisdiction, so OSHA doesn’t enforce their content.5Occupational Safety and Health Administration. Hazard Communication Standard: Safety Data Sheets
Labels changed too. Manufacturers can no longer use whatever warning symbols they choose. GHS-compliant labels require standardized pictograms (red-bordered diamonds with specific symbols inside), a signal word of either “Danger” or “Warning,” and standardized hazard statements.3eCFR. 29 CFR 1910.1200 – Hazard Communication The eight pictograms cover flame, exploding bomb, skull and crossbones, corrosion, gas cylinder, health hazard, exclamation mark, and environment. The environment pictogram is not mandatory under OSHA but appears on many labels. Each pictogram can appear only once per label, even when multiple hazard categories would trigger the same symbol.6Occupational Safety and Health Administration. Hazard Communication Standard Pictogram
What Employers Have to Do Now
Employers must keep a current SDS for every hazardous chemical in the workplace and make those sheets readily accessible to employees during every work shift. “Readily accessible” means employees can get to the information without leaving their work area. Electronic systems (tablets, computers, cloud-based databases) satisfy this requirement, provided there are no barriers to immediate access and a backup plan is in place if the system goes down.7eCFR. 29 CFR 1910.1200 – Hazard Communication
For employees who move between job sites during a shift, the SDS collection can be kept at the primary workplace, as long as workers can get the information immediately in an emergency. Laboratories follow a simpler rule: employers keep any SDS that arrives with incoming chemical shipments and make them accessible to lab employees during their shifts.7eCFR. 29 CFR 1910.1200 – Hazard Communication Chemical manufacturers and importers must update an SDS within three months when new hazard information comes to light.
Training is a separate obligation. Employees must be trained at the time of their initial assignment and again whenever a new chemical hazard is introduced into their work area. Waiting until a quarterly safety meeting to cover a chemical that arrived last month puts the employer out of compliance. The training has to cover the labeling system the employer uses, how to read an SDS and find information in it, how to detect the presence of hazardous chemicals, the physical and health hazards those chemicals present, and the available protective measures. Employers must also tell employees where the written hazard communication program and the chemical list are kept.8Occupational Safety and Health Administration. 1910.1200 – Hazard Communication
Penalties for Falling Behind
Hazard communication violations consistently rank among OSHA’s most cited. The standard came in second on the agency’s list for fiscal year 2025. Common citations include failing to maintain accessible SDS documents, incomplete written programs, and inadequate employee training.
As of January 2025, a serious or other-than-serious OSHA violation carries a maximum penalty of $16,550 per violation. Willful or repeated violations can reach $165,514 per violation, and these figures are adjusted annually for inflation.9Occupational Safety and Health Administration. 2025 Annual Adjustments to OSHA Civil Penalties Each missing SDS, each untrained employee, and each labeling failure can be cited separately, so a workplace with systemic gaps can accumulate a substantial bill quickly.