Q&A on OSHA's new safety data sheet standards helps you stay compliant

The lack of a ‘hazard communication’ plan is reportedly the second-most-cited OSHA violation–and safety data sheets are an important part of that plan. Check out some common OSHA questions, answered.

Two female veterinary professional work work on a computer inside a clinic.
Put a quick-access link on each computer or tablet in your clinic to access SDS software immediately. Photo courtesy Patterson Veterinary

A quick search on the Occupational Safety and Health Administration (OSHA) website for requirements for the veterinary industry reveals … nothing. Well, not really. However, it is not easy to find answers about how OSHA regulations impact the industry, especially when you start looking deeper into topics such as Hazard Communication Standards and Safety Data Sheets (SDS).

A summary of changes and deadlines

OSHA modernized its standards in 2024, and the first of the new regulations is set to go into effect this year.

Veterinary manufacturers were required to update their SDS for substances to the new format on January 19, 2026, with mixtures following in July of 2027. The same requirements trickle down to clinics that use these products, which means veterinary teams should invest some time and attention in safety documentation prior to the enforcement date.

To remain HazCom (Hazard Communication Standards)-compliant, practices must have updated SDSs for all substances on hand by July 20, 2026.

SDS fall under the purview of the U.S. Department of Labor to ensure Americans have safe and healthy work environments. As one of the five key elements in your required Hazard Communication Program, you will need an SDS for every chemical and hazardous material in your practice.

Each SDS includes everything from common names and synonyms for the product, manufacturer information and recommended use, first aid measures, and handling and storing of materials to melting points and toxicological information, all broken out into 16 sections that have been internationally standardized into a Globally Harmonized System (GHS).

SDS materials were standardized using the GHS to facilitate international communication. As part of this effort, pictograms were developed for use on SDS documents.

According to the OSHA website Top 10 Most Frequently Cited Standards for Fiscal Year 2024 post, lack of a 'Hazard Communication' plan was the second-most-cited OSHA violation – and safety data sheets are an important part of that plan.

Here are some common OSHA questions, answered:

1) Can we look up SDSs online in lieu of a paper binder?

Technically, yes. To clarify, you can keep your forms digitally, but they cannot be housed behind any other barrier of entry, such as a password.

Consider that hunting for safety data sheets online can be slow or time-consuming in safety situations that require speedy intervention.

Note: Most practices have an average of 300 products that require SDS, and OSHA requires them to be up to date for the last 30 years, regardless of whether or not the substance is still in your clinic.

2) What should I do if I'm having trouble finding a manufacturer's SDS? Can I substitute with an equivalent?

If you have exhausted all other options in locating a manufacturer's SDS, your last resort is to directly contact the manufacturer by phone or email to request they provide the
SDS document.

Theoretically, generic and brand-name products with the same ingredients should have nearly identical SDS. There can be slight formulation differences; however, that would not make generic and brand-name SDS interchangeable.

It is always best to use the SDS that directly corresponds to the product you have, from the manufacturer or supplier you got it from. Similarly, an SDS for an equivalent product should not be considered interchangeable.

3) Do the same rules apply to colleges? Do I need SDS for the supplies that sit on veterinary students' desks?

Yes. If you have purchased a product in bulk and divided it into secondary containers. For example, each spray bottle requires its own label.

4) Do I need to worry about SDS compliance if I'm a small one-doctor practice?

Yes, OSHA compliance is legally required regardless of the size or type of practice or facility, or its location, whether single doctor, mobile, equine, etc.

5) How often do OSHA inspections happen?

OSHA does not have a specific timeline for inspections. The frequency of OSHA inspections can vary depending on several factors, such as industry, types of hazards present, employee complaints, company size, and incident rates.

While low-hazard sites may experience inspections much less frequently than high-hazard sites, for example, an OSHA inspection can happen at any time, so it is important to maintain continuous compliance.

6) Are SDS for medications and chemicals the same? What do the sheets look like?

No. While they follow a similar standardized format, the specific content and details may vary depending on the purpose and hazards associated with each.

Both medication and chemical SDS cover identification, composition, handling procedures, and health effects. However, medications focus on medical use, while chemical SDS focus on safe industrial use, as regulated by OSHA. The product labels also reflect a difference in purpose through the information highlighted.

7) Are there downsides to keeping an SDS binder?

While the veterinary industry has seen a broad shift towards paperless, digital solutions, many clinics still use binders to manage their SDS. This method can meet OSHA requirements—though it can be labor-intensive and leaves room for human error.

Manufacturers regularly update their SDS materials, and a practice would need to stay informed on changes to each sheet for hundreds of products to ensure they have the correct version. Plus, they would need to archive and house older versions to meet the Employee Exposure Records requirement, even if the substance is no longer in clinic.

A wide shot of a veterinary clinic.
Harmony Animal Hospital in Alexandria, Va., has used SDS software for its "set it and forget it" aspect. Photo courtesy Patterson Veterinary

Another potential issue is that paper binders tend to become scarce or hard to physically locate within the practice. This means it is not a fast way to get safety information when the team needs it and it does not meet OSHA requirements for "readily available." Be mindful of these pain points when deciding how to approach safety in your clinic and with your team.

Three-ring binders are a holdover from days when we also used paper medical records. Everything is digital, and SDSs are now, too. Look for software that can keep track of, update, and house these sheets, and is customized to your clinic.

10 common OSHA violations

Sandy Walsh, RVT, CVPM, a veterinary practice management consultant with more than 35 years of experience in the industry, shares the following most common violation she sees:

  1.  No hazard communication program
  2. No certification of personal protective equipment assessment
  3. No fire and emergency plans
  4. Poor employee training documentation
  5. Lack of safety data sheets
  6. Inappropriate personal protective equipment
  7. Poor or no chemical labeling
  8. OSHA forms not utilized
  9. Human food in unsafe areas
  10. No control of waste anesthetic gases

Since OSHA requires the information be readily available, setting up a quick-access link on every computer or tablet in your practice ensures it is readily accessible. Plus, it frees up anyone on your team from having to dedicate administrative time to SDS upkeep, so you can focus on patients instead.

Tip: Put a quick-access link on each computer or tablet in your clinic to access SDS software immediately.


Staci Thorne, RVT, is Patterson Veterinary's senior manager of software and is a certified veterinary technician with more than a decade of hospital experience. Her product portfolio includes AutoSDS software that customizes and automates SDS for clinics.

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