Material Safety Data Sheets (MSDS) Update from Randi Q. When is a Material Safety Data Sheet (MSDS) not required? A. Chemical manufacturers and importers must develop a MSDS for each hazardous chemical that they produce or import, and must provide the MSDS automatically at the time of the initial shipment of a hazardous chemical to a distributor or user. Distributors must also ensure that employers are similarly provided an MSDS. Consumer Products OSHA does not require employers to maintain MSDS's for consumer products when they are used in the manner for which they were intended, and when employees’ exposures to the product on the job are similar to their exposures when using the product off the job. For example, is the employer required to have an MSDS for a floor detergent that an employee uses periodically to clean floors in the workplace? This depends on the frequency and the type of detergent. Because the employee is using the floor detergent as a floor cleaner, which is its intended use, and the employee’s exposure to the detergent is no greater on the job than off the job, the employer does not have to maintain an MSDS for the cleaner.

In contrast, if the employee uses this same detergent eight hours a day to clean equipment throughout the facility, then an MSDS would be required. This is because the employee’s on-the-job exposure is greater than his or her off the job exposure, and the product is not being used for its intended purpose. Articles Articles are items that generally do not pose a physical hazard or health risk to employees. As a rule, OSHA does not require an MSDS for articles containing hazardous materials. However, if the article is altered in such a way that hazardous materials can leak out, or leak out, or cause an employee exposure, then the employer must have an MSDS on file. An example is lead acid batteries. As long as the hazardous materials are contained within the battery, and leakage of the battery fluid is not probable, then an MSDS is not required. However, if the employees handle or use the lead acid batteries in a manner that compromises the battery, resulting in leakage of battery acid, the employer must have a lead acid battery MSDS on file.