HazCom (1910.1200) does not require storing MSDS/SDSs for 30 years. However, OSHA Standard 29 CFR 1910.1020 (Access to Employee Exposure and Medical Records) includes MSDS/SDS as an employee exposure record with the 30-year retention requirement.
Here's what you need to know:
- OSHA requires employers provide employees and their designated representatives a right of access to relevant exposure and medical records
- SDSs/MSDSs are named as a record of exposure to toxic substances or harmful physical agents.
- If you don't keep SDSs, you must maintain detailed records of the specific chemical identity, where it was used, and when it was used.
- These records are required to be kept for at least 30 years,
The often-cited "30-year rule" doesn't come from HazCom. It comes from OSHA Standard 29 CFR 1910.1020 (Access to Employee Exposure and Medical Records). Below, we break down the most common questions safety professionals have about SDS/MSDS retention.
SDS/MSDS Retention Questions
Do I need to keep SDSs/MSDSs for 30 years?
Yes and no. If you do not keep every SDS or MSDS for at least 30 years. You must keep a record of the identity of substances employees were exposed as well as where and when for 30 years. That said, OSHA identifies SDSs/MSDSs as a compliance record type—and in most cases, keeping them is the simplest and most reliable way to comply.
What if I don't keep the SDS/MSDS?
Then you need to maintain alternative exposure records that include:
• The chemical identity (name, CAS # or other information on precise chemical designation)
• Where it was used
• When it was used
In fact, OSHA clarified in a 1985 Letter of Interpretation that "where" and "when" details are not required on SDSs themselves—but are required if you use an inventory record instead of an SDS.
What happens if an SDS is updated or superseded?
According to a 1987 OSHA Letter of Interpretation:
• If the formulation has not changed → You may replace the old SDS/MSDS with the new one.
• If the formulation has changed → You must keep both the old and the new SDS/MSDS for at least 30 years.
What does OSHA 1910.1020 require?
The purpose of this standard is to give employees and their representatives access to exposure and medical records. Key requirements include:
• Employers must provide records within 15 working days of a request (or explain the reason for any delay and when the records will be available).
• If a company is sold or ceases operations, records must be transferred to the successor employer or to the Director of NIOSH.
How is this different from HazCom (1910.1200)?
HazCom requires that SDSs/MSDSs be readily accessible to employees during their work shift. Since you must maintain SDSs for HazCom, many employers choose to archive them for 30 years—satisfying both HazCom and 1910.1020 requirements at once.
Compliance Solution
What's the easiest way to stay compliant?
Use a modern SDS management solution. With msdsSource, you can:
• Digitally archive SDSs for 30-year recordkeeping compliance
• Provide instant employee access for HazCom requirements
• Track formulation changes and usage history
• Ensure smooth record transfers if ownership changes
• Centralize all SDSs in a secure, searchable digital database
Don't leave compliance to chance. Book a demo with msdsSource today to see how our SDS management software can simplify OSHA recordkeeping, reduce risk, and keep your workplace compliant.
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.
