SDS Safety Data Sheet Management Checklist [FREE PDF]

Safety Data Sheet (SDS) management is a cornerstone of OSHA's Hazard Communication Standard (29 CFR 1910.1200), which requires employers to maintain an SDS for every hazardous chemical used in the workplace and ensure employee access during all work shifts. Non-compliance with SDS requirements is consistently among OSHA's top 10 most-cited violations, carrying penalties up to $15,625 per violation. This checklist enables EHS Managers to systematically audit SDS library completeness, GHS format c

  • Industry: Laboratory Services
  • Frequency: Quarterly
  • Estimated Time: 30-45 minutes
  • Role: EHS Manager
  • Total Items: 36
  • Compliance: OSHA 29 CFR 1910.1200 - Hazard Communication Standard (GHS), OSHA 29 CFR 1910.1200 Appendix D - SDS Requirements (16 Sections), EPA EPCRA Sections 311-312 - Tier II Chemical Inventory Reporting, DOT 49 CFR 172.200-204 - Shipping Paper & Hazmat Documentation, NFPA 30 - Flammable and Combustible Liquids Code (Chemical Identification)

SDS Library Completeness

Verify that an SDS exists for every hazardous chemical in the facility inventory and that the library count matches.

  • Does the number of SDSs in the library equal or exceed the number of hazardous chemicals on the facility inventory list?
  • Have all chemicals received in the last 90 days had their SDSs added to the library before first use?
  • Are SDSs available for all discontinued chemicals still present in storage until disposal is complete?
  • Are SDSs maintained in GHS-compliant 16-section format for all chemicals?
  • Is a master index of all SDSs (by chemical name and CAS number) maintained and current?

GHS Format & Content Compliance

Audit a sample of SDSs to confirm all required GHS 16-section elements are present and complete.

  • Do sampled SDSs contain all 16 required GHS sections (Sections 1-16 per Appendix D)?
  • Does Section 8 of each sampled SDS include OSHA PEL, ACGIH TLV, and recommended engineering controls and PPE?
  • Does Section 14 of each sampled SDS include DOT proper shipping name, hazard class, UN number, and packing group?
  • Does Section 2 include GHS-compliant signal words, hazard statements, pictograms, and precautionary statements?
  • Is Section 15 (Regulatory Information) populated with applicable US federal and state regulations (SARA, RCRA, TSCA, state right-to-know)?
  • Are all SDSs written in English, and are translated copies available for non-English-speaking workers?

SDS Accessibility & Availability

Confirm that SDSs are immediately accessible to all employees during all work shifts without barriers.

  • Are SDSs immediately accessible to all employees during every work shift without supervisor approval or delay?
  • If SDSs are maintained electronically, is an uninterrupted power backup or printed emergency set available?
  • Is the SDS system accessible from all locations where hazardous chemicals are used or stored?
  • Are employees aware of the location of and procedure for accessing SDSs (physical binders and/or electronic system)?
  • Are contractor and visitor access procedures for SDSs documented and communicated?

SDS Updates & Currency

Verify that SDSs are current, supplier update requests are tracked, and outdated SDSs are replaced promptly.

  • Are SDSs reviewed and updated when new hazard information becomes available from suppliers?
  • Is there a documented process to request updated SDSs from suppliers when version revisions are identified?
  • Do all SDSs have a document revision date (Section 16) and are any SDSs older than 5 years flagged for verification?
  • Are superseded SDSs archived separately from active SDSs to prevent use of outdated information?
  • Is there a tracking log of SDS requests, receipts, and updates with responsible party and date recorded?

HazCom Training & Employee Awareness

Confirm that employee training on SDS content, GHS labels, and chemical hazards is documented and current.

  • Have all employees working with or near hazardous chemicals received initial GHS HazCom training?
  • Are training records (employee name, date, trainer, topics covered) maintained and accessible for at least 3 years?
  • Have employees received retraining when new chemicals or new hazard information were introduced in the last 12 months?
  • Can a sample of employees correctly identify the location of SDSs and explain how to access them in an emergency?
  • Is training provided in a language and at a literacy level understood by all employees?

Tier II Reporting & Regulatory Linkage

Verify that SDS data is being used to fulfill EPCRA Tier II chemical inventory reporting obligations.

  • Are all chemicals with SDSs cross-referenced against EPCRA Section 311/312 reporting thresholds?
  • Has a Tier II (EPCRA Section 312) report been submitted to the SERC, LEPC, and local fire department by March 1 for the prior calendar year?
  • Are chemicals subject to SARA Section 313 Toxic Release Inventory (TRI) reporting identified and tracked?
  • Are SDS Section 14 (Transport Information) data used to ensure compliant DOT shipping papers and hazmat labels?
  • Are SDS records for chemicals with potential employee exposures retained for the 30-year period required by OSHA medical records standards?

SDS System Management & Program Review

Assess the overall effectiveness, ownership, and continuous improvement of the SDS management program.

  • Is a designated SDS program administrator (owner) identified with documented responsibilities?
  • Is the written HazCom program reviewed and updated at least annually or when significant changes occur?
  • Are purchasing controls in place to ensure new chemicals undergo SDS and compatibility review before procurement approval?
  • Are deficiencies identified in previous SDS audits documented, assigned corrective actions, and verified as closed?
  • Is the SDS management audit itself documented and retained as part of the facility's HazCom program records?

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Why Use This SDS Safety Data Sheet Management Checklist [FREE PDF]?

This sds safety data sheet management checklist [free pdf] helps laboratory services teams maintain compliance and operational excellence. Designed for ehs manager professionals, this checklist covers 36 critical inspection points across 7 sections. Recommended frequency: quarterly.

Ensures compliance with OSHA 29 CFR 1910.1200 - Hazard Communication Standard (GHS), OSHA 29 CFR 1910.1200 Appendix D - SDS Requirements (16 Sections), EPA EPCRA Sections 311-312 - Tier II Chemical Inventory Reporting, DOT 49 CFR 172.200-204 - Shipping Paper & Hazmat Documentation, NFPA 30 - Flammable and Combustible Liquids Code (Chemical Identification). Regulatory-aligned for audit readiness and inspection documentation.

Frequently Asked Questions

What does the SDS Safety Data Sheet Management Checklist [FREE PDF] cover?

This checklist covers 36 inspection items across 7 sections: SDS Library Completeness, GHS Format & Content Compliance, SDS Accessibility & Availability, SDS Updates & Currency, HazCom Training & Employee Awareness, Tier II Reporting & Regulatory Linkage, SDS System Management & Program Review. It is designed for laboratory services operations and compliance.

How often should this checklist be completed?

This checklist should be completed quarterly. Each completion takes approximately 30-45 minutes.

Who should use this SDS Safety Data Sheet Management Checklist [FREE PDF]?

This checklist is designed for EHS Manager professionals in the laboratory services industry. It can be used for self-assessments, team audits, and regulatory compliance documentation.

Can I download this checklist as a PDF?

Yes, this checklist is available as a free PDF download. You can also use it digitally in the POPProbe mobile app for real-time data capture, photo documentation, and automatic reporting.

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