Are MSDSs Required for Consumer Chemical Products?

Just back from the American Society of Safety Engineers (ASSE) show in San Antonio.  Great show and thanks to all that stopped by our booth.  A number of people at the show asked me if material safety data sheets (MSDSs) are required for consumer products like Windex or Lysol?

This is a common question we receive; especially now, with companies focusing more on safety and compliance in response to OSHA ramping up its regulatory enforcement efforts.

When Are SDSs Required for Consumer Products?

In general, the OSHA Hazard Communication Standard (HCS) requires businesses to have Material Safety Data Sheets (MSDSs) for all potentially  hazardous chemicals present at a work site.  But the answer more accurately lies in how your employees use these types of products at your workplace.

Essentially, if your employees use consumer chemical products in the same manner that any other consumer would, and as directed by the manufacturer, you probably don’t need to worry about having an MSDS.

On the contrary, however, if your employees use consumer chemical products for purposes that extend beyond that of an average consumer, especially in regards to the frequency and quantity of use, then their exposure rate is higher and you most likely do need to supply MSDSs for those products.

Consumer Use vs. Workplace Use: Two Examples

Here are a couple of real-world use scenarios:

Scenario 1: An employee  uses a disinfectant spray to clean off a desk or work area once or twice a day. This squarely falls into the “as directed by the manufacturer,” camp and would constitute a consumer use of that product. Therefore, you would not be required to provide an MSDS.

Scenario 2: The employee uses the same disinfectant spray in a health care setting to continually clean and disinfect numerous surfaces throughout the workday.  In this case, the frequency of use would likely constitute non-consumer use of the product.  Therefore, you would be required to incorporate that product into your HCS program and provide the appropriate MSDS and training for your employees.

What to Do If You’re Unsure About SDS Requirements

When thinking about this, let common sense be your compass.  And, as we tell our customers, better safe than sorry… there’s no penalty for erring on the side of caution.  If you’re unsure, better to simply have the MSDS.

For more information on this topic, we recommend reading the OSHA Letter of Interpretation titled, “Requirements for maintaining material safety data sheets (MSDSs) for consumer art products and office cleaning products.”

We hope this helps.  If you have other questions regarding your MSDS compliance requirements, let us know.

Simplify SDS Compliance and Chemical Management

Knowing when an SDS is required is just one part of maintaining an effective Hazard Communication program. You also need to keep required SDSs up to date, accessible, and easy for your people to find.

VelocityEHS Chemical Management software makes it easier to maintain an updated SDS library your people can access 24/7, while Safety software helps you manage other core safety tasks, including inspections, safety meetings, incident investigations, and corrective actions.

Need deeper insight into your chemical inventory? VelocityEHS Chemical Management software can help you identify chemical ingredients within your SDSs, cross-reference them against regulatory lists, and surface key information you need to understand and manage chemical hazards.

VelocityEHS also offers SDS and chemical management capabilities aligned with OSHA’s 2024 final rule updating the HazCom Standard to align primarily with Revision 7 of the GHS.

Ready to simplify HazCom compliance? Explore our Safety and Chemical Management solutions, or contact us to schedule a demo.