Safety Data Sheets at a Dealership: What Has to Be Kept, Where and for Whom?

1.You Need an SDS for Each Hazardous Chemical You Use

OSHA requires employers to have a Safety Data Sheet in the workplace for each hazardous chemical they use. The Hazard Communication Standard applies when a hazardous chemical is known to be present in a way that employees may be exposed during normal use or in a foreseeable emergency.

That does not mean every product purchased by the dealership automatically requires an SDS. But if a product is a hazardous chemical covered by the standard and employees use it in the workplace, the dealership needs the required information.

A good SDS program therefore starts with the chemicals actually present at the facility, not with whatever happens to be sitting in an old three-ring binder.

2.The Chemical Inventory and the SDS Library Should Agree

OSHA requires the written Hazard Communication program to include a list of hazardous chemicals known to be present. The product identifier on that list needs to reference the appropriate SDS.

In practical terms, the chemical inventory and SDS library should talk to each other.

If the inventory says the dealership uses Product A, somebody should be able to find the SDS for Product A. If the SDS system contains 900 sheets but nobody can tell which 75 products are actually in the building, the dealership may have a large database without having a particularly useful Hazard Communication system.

3.Employees Need Ready Access During Their Work Shift

OSHA requires the SDSs to be readily accessible during each work shift to employees while they are in their work areas.

The important word is accessible. Employees should know where the information is and how to get to it. An SDS system that exists only in the service manager's locked office is not much help to a technician who needs chemical information when that manager is at lunch.

OSHA has also explained that employees should not have to go through a supervisor simply to obtain an SDS. The information needs to be available when employees need it.

4.Yes, SDSs Can Be Electronic

OSHA does not require a paper SDS binder. Electronic access and other alternatives are permitted as long as they do not create barriers to immediate employee access.

For many dealerships, an electronic SDS library is considerably easier to maintain than several binders scattered around the facility. It can also make updates and searching much easier.

But putting SDSs "online" is not enough by itself. Employees need to know how to reach them. The system needs to be available during the work shift. And the dealership should think through what happens if the normal access method is temporarily unavailable.

The test is not paper versus electronic. The test is whether the employee can get the required information without an access barrier.

5.The SDS Is More Than an Emergency Document

The modern SDS follows a standardized 16-section format. Among other things, it provides information on hazard identification, ingredients, first aid, firefighting, accidental releases, handling and storage, exposure controls, personal protection and physical properties.

Employees do not need to memorize an SDS. They do need to understand how the dealership's Hazard Communication system works and how to obtain and use the hazard information.

OSHA requires Hazard Communication training at initial assignment and whenever a new chemical hazard for which employees have not previously been trained is introduced into their work area.

6.Do Not Forget Secondary Containers

SDSs are only one piece of Hazard Communication. Workplace labeling matters too.

When hazardous chemicals are transferred into other workplace containers, those containers generally need appropriate hazard information under OSHA's workplace-labeling rules.

There is an exception for a portable container intended only for the immediate use of the employee who transferred the chemical. That exception is narrow. The mystery spray bottle that has been sitting on a detail cart for three days is not what OSHA means by immediate use.

Dealerships should make secondary-container labeling part of the same walkthrough used to check the chemical inventory and SDS system.

7.Contractors Can Make Hazard Communication a Two-Way Street

Dealerships regularly have outside people on site. Equipment installers, maintenance contractors, cleaners and other vendors may work in areas where hazardous chemicals are present.

OSHA's multi-employer Hazard Communication provisions require employers to address how other employers on site will get access to SDSs for hazardous chemicals their employees may encounter, along with applicable precautions and information about the workplace labeling system.

The dealership also needs to consider hazards introduced by contractors that could affect dealership employees. Hazard Communication should not stop at the edge of the dealership's payroll.

8.Do You Have to Keep Every Old SDS Forever?

This is an area where two OSHA standards can get confused.

The Hazard Communication Standard requires current SDSs for hazardous chemicals in use to be readily accessible. OSHA's employee exposure and medical records requirements create a separate long-term recordkeeping issue.

OSHA has explained that an SDS itself does not necessarily have to be retained for 30 years if the employer preserves the required record of the identity of the chemical, where it was used and when it was used for the required period.

From a management standpoint, that means the active SDS library does not need to become an archaeological dig through every chemical the dealership has purchased since the fax machine was cutting-edge technology. Current access and historical recordkeeping are related, but they serve different purposes.

9.When a New Chemical Shows Up, the System Needs to Know About It

One of the easiest ways for an SDS program to get out of date is decentralized purchasing.

A technician finds a better cleaner. Detail orders a new product. Parts changes suppliers. The collision center tries a different coating. Six months later, the product is being used every day but never made it into the chemical inventory or SDS system.

OSHA requires manufacturers, importers and distributors to provide SDS information through the supply chain. If a hazardous chemical arrives without the required SDS, the employer should obtain it as soon as possible.

The dealership's internal process should make sure new hazardous chemicals are reviewed, added to the inventory, added to the SDS system and addressed in training when they introduce a new hazard.

10.Hazard Communication Is Changing, So Watch for Updated SDSs

OSHA updated its Hazard Communication Standard in 2024 to align primarily with a newer revision of the Globally Harmonized System. Among other changes, the rule affects hazard classifications, labels and portions of the SDS.

OSHA later extended the compliance dates. As of August 2026, manufacturers, importers and distributors evaluating substances were required to comply with the modified provisions by May 19, 2026. Employers have until November 20, 2026, as necessary, to update workplace labeling, their Hazard Communication program and employee training for newly identified hazards involving substances.

The corresponding compliance dates for mixtures extend into 2027 and 2028.

For a dealership, the practical lesson is not to panic and rebuild the SDS library from scratch. Pay attention to updated SDSs and labels received from suppliers, keep the active chemical inventory current and make the required program or training changes when newly identified hazards affect the workplace.

The Bigger Picture

A good SDS program is not measured by the thickness of the binder or the number of files in a database.

It is measured by whether the dealership knows what hazardous chemicals it has, has the correct information for those chemicals and can put that information in an employee's hands when it matters.

Walk the shop. Pick five chemical products at random. Can you find all five on the chemical inventory? Can you pull up the SDS for each one? Can a technician do the same thing without asking three people for help?

If the answer is yes, you probably have a useful system. If not, the problem is worth fixing before somebody needs that information in an emergency.