At least to my quick understanding, SDSs posted on your websites would fall under the "Preexisting conventional electronic documents" exception, as long as they were available prior to the accessibility deadline (here's a direct link to the exceptions in the official regulation). Any new SDSs or updated versions posted after the compliance deadline would fall under accessibility requirements, however.

It should be noted that while there's also an exception for content created by a third party, the use case of "a university posting a third-party-created PDF on their web site" does not appear to fall under that exception.

I expect that the "best" way forward for SDSs specifically is for institutions to demand en masse that their chemical vendors provide WCAG-accessible SDSs, particularly when it comes time to renegotiate any purchasing agreements or contracts.

Regards,

Andrew

 

Andrew H. Chung, M.S., CCHO

Chemical Hygiene Officer

Environment, Health, and Safety

University of California, San Francisco  

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From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU> on behalf of van de Wouw, Heidi <0000242332f49449-dmarc-request**At_Symbol_Here**LISTS.PRINCETON.EDU>
Sent: Friday, January 30, 2026 11:34 AM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Subject: Re: [DCHAS-L] Fwd: SDS PDF Accessibility and Title II - What Guidelines Are Others Using?

 

Hello DCHAS, I am re-reaching out to inquire if anyone has anything to update since this main ask last October? My school is just now trying to figure out a process for SDSs and hoping to help in any way that I can. Any other interesting resources

Hello DCHAS,

I am re-reaching out to inquire if anyone has anything to update since this main ask last October? My school is just now trying to figure out a process for SDSs and hoping to help in any way that I can.

Any other interesting resources that align Title II compliance and safety resources would be greatly appreciated as well.

Thank you,

Heidi van de Wouw

-_-_-_-_-_-_-_-_-_-_-_-_-_-_-_-_-_-_-_-_-

 

Dr. Heidi L. van de Wouw

 

Academic Professional 

School of Chemistry & Biochemistry

Georgia Institute of Technology

 

E-mail:  Heidi.vandeWouw**At_Symbol_Here**chemistry.gatech.edu

Phone:   (404) 385-0631

Office:   Boggs 2-90C

Advising:   Navigate360

 

 

From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU> on behalf of Jeffrey Lewin <jclewin**At_Symbol_Here**MTU.EDU>
Date: Wednesday, October 22, 2025 at 3:59 PM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU <DCHAS-L**At_Symbol_Here**Princeton.EDU>
Subject: Re: [DCHAS-L] Fwd: SDS PDF Accessibility and Title II - What Guidelines Are Others Using?

You don't often get email from jclewin**At_Symbol_Here**mtu.edu. Learn why this is important

Interesting question. 

We use VelocityEHS (formally MSDSonline) for managing our sds .pdfs.

I opened a SDS .pdf for Acetonitrile.  I never knew this, but embedded in the program is "open in Acrobat" (that opens an Adobe .pdf window).  I then picked "voice option" and it read to me...but there were some hitches..

I'm not sure if the embedded picture shows up in this email, but when it got to Product identifiers it read them going down the column:

Product name

Product Number

Brand

Index "No" [pronounced like the word "no"]

Cas No [pronounced this as "Cass no"

Then it went down the other column:

Acetonitrile 

34851

Sigald

608-001-00-3

75-05-8 [Which it read as August 8, 1975 NOT as individual numbers]

In addition to pronunciation (and the date) error, it was a bit confusing since it separated the columns, i.e. 

NOT reading it as 

Product name Acetonitrile

Product number 34851

etc...

Jeff

On Tue, Oct 21, 2025 at 2:03 PM Membership DCHAS <membership**At_Symbol_Here**dchas.org> wrote:

Hello, 

I’m looking into how other higher ed institutions are handling SDS PDFs for internal electronic storage and distribution and on their public websites for those who have them posted online through their chemistry departments or through their EHS websites, especially in light of the Title II federal guidelines around accessibility (ADA web / document accessibility). I’m wondering whether any colleges or state institutions you know of have formal guidelines, policies, or best practices they follow (or have developed) for meeting Title II requirements and continuing to allow SDS to be distributed electronically and/or be accessible online. (We keep paper as well, but want to ensure our SDS continue to be broadly accessible to the broadest audience within the context of the Title II updates.)

A few specific questions I’d love to crowdsource perspectives on:

• Are you aware of any colleges or universities that allow SDS/PDF documents on their websites and currently meet Title II accessibility standards (e.g. tagged PDF, reading order, alt text)?
• Are there any remediation strategies used by other colleges to convert legacy SDS PDFs into accessible format, or are institutions taking them offline, or direct linking rather than hosting pdfs? 
• What reservations do folks have about that type of pdf remediation
• Are there reservations about direct linking to company websites (broken links, slow updates, etc)
• Are there any institutions that would be willing to share their internal “SDS accessibility” guidelines or checklists (so we could see how they handle legacy versus newly published SDSs)?
• And related, are any institutions have formal policy they're willing to share about SDSs PDFs for electronic distribution in the context of Title II as part of their accessibility strategy?

If folks are aware of any published policies or institutions who’ve done this work, that would be very helpful. I am assembling a comparative survey of how peers are handling SDS accessibility, and would be grateful for your assistance.

Thanks for any insight,

-Dan Jacques

---------------------------------------------------

Daniel R. N. Jacques, MS

Chemistry Laboratory Safety Manager; Chemistry Instructor

Instructional Support Specialist, SL4

Pronouns: He/Him/His

Chemistry and Biochemistry - Smith 230

SUNY Brockport, 350 New Campus Drive, Brockport, NY 14420

Office: (585) 395-2480

American Chemical Society Committee on Chemical Safety Member 

Chancellor's Award for Excellence in Professional Service, 2017

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Jeff Lewin

Chemical Safety

Environmental Health and Safety

Office of the General Counsel

Michigan Technological University

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