Author: Angela Wheeler
Understanding OSHA Requirements for SDSs in U.S. Workplaces
Consumer products such as cleaners, disinfectants, glues, and aerosols are used in many workplaces and employers often ask:
Do consumer products require a Safety Data Sheet (SDS) under OSHA’s Hazard Communication Standard (HCS)?
This article explains the OSHA rules, clarifies the consumer-product exemption, and helps employers determine when an SDS is required.
What Is a Safety Data Sheet (SDS)?
A Safety Data Sheet is a 16-section standardized document required by OSHA for hazardous chemicals used in the workplace. SDSs provide essential safety information, including:
- Physical and health hazards
- Safe handling and storage instructions
- PPE requirements
- Emergency and first-aid procedures
- Environmental precautions
Although many people still say “MSDS,” the modern GHS-SDS format replaced it in 2012.
OSHA’s Consumer Product Exemption: The Answer
Under the OSHA Hazard Communication Standard (29 CFR 1910.1200), certain consumer products are exempt from SDS requirements — but only when used the same way and with the same frequency as a typical consumer would at home.
Common situations where the exemption applies:
- Occasional use of bleach spray in an office break room
- An employee using hand sanitizer or lotion
- A staff member using household-grade window cleaner once a week
In these cases, OSHA does not require an SDS, training, or hazard communication labeling beyond what’s on the retail packaging.
When a Consumer Product Does Require an SDS
A consumer product must be treated as a workplace hazardous chemical — and must have an SDS — when:
1. Workplace exposure is greater than typical household use
If employees use the product more frequently or for longer durations, the exemption no longer applies.
Examples:
- Custodial staff using disinfectants daily
- Maintenance workers applying caulks, sealants, or adhesives routinely
- Regular use of retail paints, solvents, or aerosols
2. The quantity used increases the hazard
Large-scale or industrial-style use increases the exposure level.
3. The product’s hazards increase during workplace tasks
Mixing, heating, spraying, or decanting can release more vapor or increase skin contact risks.
4. Employees could experience health or physical hazards
Even everyday cleaners can cause respiratory irritation, skin burns, or fire when used frequently or improperly.
In any of these cases, employers must obtain, maintain, and train workers on the SDS.
Employer Responsibilities Under OSHA’s Hazard Communication Standard
To stay compliant, U.S. employers must:
✔ Maintain SDSs for all hazardous chemicals
This includes consumer products used above normal consumer frequency.
✔ Ensure SDSs are accessible to employees during every shift
Either electronic or physical access is acceptable.
✔ Provide hazard communication training
Employees must understand the hazards and safe-use procedures for chemicals they work with.
✔ Quarantine hazardous products without an SDS until one is obtained
If a supplier or manufacturer does not provide an SDS upon request, the product should not be used.
✔ Keep an updated chemical inventory
Consumer products used industrially should be included in your chemical inventory if they are hazardous.
Why “Consumer-Grade” Doesn’t Always Mean “No-Hazard”
Even products sold at retail stores can pose significant hazards when used in a workplace setting. The key compliance question is not what the product is, but how it is used.
Factors that can increase workplace hazards and exposure to workers include:
- Frequent or continuous use
- Use in enclosed spaces
- Aerosolization or spraying
- Use near heat sources
- Large-quantity storage
- Chemical mixtures or reactions
Whenever the risk of exposure to workers increases, OSHA’s SDS requirements apply.
Summary: Do Consumer Products Need an SDS?
Here is the simple rule:
If your employees use a consumer product the same way a consumer would at home, an SDS is usually NOT required.
IF the product use is greater, an SDS MUST be maintained.
Employers should evaluate each consumer product based on frequency, duration, quantity, and exposure level.
When in doubt, maintaining an SDS is the safest and most compliant choice.
For More Information on SDS Management
To learn more about SDS/MSDS management needs, chemical inventory control, and workplace compliance tools, visit MSDS Source.
Schedule a demo or request a quote today: www.msdssource.com
About the Author
Angela Wheeler, CIH, CSP, SDSRP is a certified industrial hygienist, certified safety professional, and SDS & Label Authoring Registered Professional with over 25 years of experience helping suppliers navigate complex regulatory requirements in manufacturing, and energy navigate complex regulatory requirements. Angela Wheeler is employed by Chemscape which is affiliated with msdsSource; both companies are owned by Quadshift inc.
This guide is intended as general information and does not replace the Regulation or legal advice. Always consult the official OSHA website for complete requirements.
