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OSHA Hazard Communication Letters of Interpretation
Retention of superseded safety data sheets
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
- Record-standard history
- 1910.20 at issuance; now 1910.1020
ILPI assessment: Retention principle retained; preserve identity and use history
This letter addresses the HCS as expanded in 1987, an obsolete version of the Hazard Communication Standard. Its record-retention principle remains relevant. Qualifying SDSs are employee exposure records under 1910.1020(c)(5)(iii); paragraph (d)(1)(ii) generally requires exposure records to be retained for at least 30 years. The record standard was formerly numbered 1910.20; OSHA's current copy of this letter uses 1910.1020.
The alternative in paragraph (d)(1)(ii)(B) permits retaining a record of the substance/agent identity (chemical name if known), where used, and when used for at least 30 years instead of retaining every old sheet. Merely seeing the same ingredient names on a replacement SDS is not enough unless the required historical information is preserved. Keep current workplace SDSs under the HCS access requirement; see the FAQ on employer SDS responsibilities.
Last reviewed: .
About this ILPI assessment
This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter. This assessment reflects editorial judgment informed by human review and AI assistance. It is an opinion, may contain errors or omissions, and is not an official OSHA determination. For guidance on how OSHA requirements apply to your circumstances, contact your local OSHA office.
OSHA's notice about interpretation letters
The following notice is published on OSHA's interpretation pages; it is general guidance, not a letter-specific withdrawal notice.
OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.
Source: OSHA's original letter page.
October 1, 1987
Mr. Dudley Robinson
Director of Government Affairs
Printing Industry of Illinois-Indiana Association
70 East Lake Street
Chicago, Illinois 60601
Dear Mr. Robinson:
This is in response to your letter of September 1, requesting an interpretation of the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard.
Specifically, your letter addresses the problem of what to do with superseded material safety data sheets. The Hazard Communication Standard requires that employers maintain copies of material safety data sheets for each hazardous chemical used in the workplace. Employers may discard a material safety data sheet for a mixture, if the new data sheet includes the same hazardous chemicals as the original formulation. If the formulation is different then the employer must maintain both data sheets for at least 30 years. OSHA standard, 29 CFR 1910.1020, Access to employee Exposure and Medical Records defines "employee exposure records" to include material safety data sheets. The standard requires all employee exposure records to be maintained for at least 30 years.
[ILPI note: Current counterparts: exposure-record retention and identity/where/when alternative, plus current SDS access. Preserve required historical information before discarding a sheet; matching ingredient names alone do not establish that the retention alternative is satisfied. OSHA's page uses the current record-rule number 1910.1020; it was formerly 1910.20. The original-text links identify the 1980 final record-access rule (PDF) as historical background; this is not a complete comparison of every intervening amendment. The current counterparts above govern today's retention duties.]
An alternative to keeping both data sheets, however, is provided for in 29 CFR 1910.1020. Under paragraph (d)(1)(ii)(B) of this standard employers may discard material safety data sheets if some record identifying the substances used, where it was used and when it was used is retained for at least 30 years. Therefore, an employer may discard the original data sheet and retain only the new data sheet if a record on the original formulation is maintained.
I hope I have clarified this issue for you. Please feel free to contact us again.
Sincerely,
John A. Pendergrass
Assistant Secretary
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1987-10-01.