Beyond the SDS: Building a Stronger Chemical Management Program
As HazCom 2024 implementation continues, employers should look beyond document management to ensure chemical inventories, workplace labels, ingredient information and employee training work together to protect workers.
For many employers, chemical management begins and ends with Safety Data Sheets (SDSs). Ask what their chemical management system does, and the first response is often, "It stores our SDSs."
That's understandable. Maintaining an up-to-date SDS library remains one of the most visible and fundamental requirements of OSHA's Hazard Communication (HazCom) Standard. Employees need ready access to hazard information, emergency responders rely on SDSs during incidents and employers are responsible for ensuring those documents remain current.
But as OSHA's revised HazCom Standard (HazCom 2024) moves through its compliance timeline, organizations throughout the chemical supply chain should recognize that compliance readiness extends well beyond managing SDSs.
While manufacturers, importers and distributors face significant responsibilities for updating classifications, labels and SDSs, downstream chemical users also have work to do. As revised information enters the workplace, employers need processes to evaluate inventories, update workplace labels and written programs, and ensure employees understand new hazard information.
In other words, SDS management remains essential, but it's only one component of an effective chemical management program.
SDSs Are the Foundation, Not the Entire Program
There's no question that SDSs are indispensable. They provide critical information about a chemical product's hazards, ingredients, safe handling procedures, required personal protective equipment (PPE), first aid measures, storage recommendations and emergency response guidance.
Without accurate and accessible SDSs, organizations cannot fully meet HazCom requirements or provide workers with the information they need to work safely.
However, maintaining thousands of SDSs in a database does not automatically improve workplace safety if you're not using that information.
Effective chemical management helps organizations understand their entire chemical landscape and use that information to make better decisions about compliance, risk reduction, industrial hygiene, environmental reporting and operational performance.
As HazCom 2024 implementation continues, employers have an opportunity to look beyond document management and evaluate whether they truly understand the chemicals being used throughout their facilities.
Start With a Complete Chemical Inventory
Every mature chemical management program begins with a complete and accurate chemical inventory.
Under HazCom, employers must maintain a list of hazardous chemicals present in the workplace as part of their written HazCom Program. In practice, however, an effective inventory should provide much more than a simple product list.
Organizations should know:
- Which hazardous chemicals are present
- Where they are stored
- What quantities are on site
- How they move through the facility
- How much is used over time
This information supports far more than regulatory compliance. It provides the foundation for emergency planning, exposure assessments, purchasing decisions and regulatory reporting.
Managing inventory product names alone isn't enough because many commercial products have names that reveal little about their actual contents. A cleaner, coating, lubricant or solvent may contain regulated ingredients that trigger reporting obligations or require additional workplace controls. Without visibility into those ingredients, organizations may struggle to identify chemicals of concern before they become compliance or safety issues.
Why Ingredient-Level Visibility Matters
Increasingly, chemical regulations focus on individual chemical constituents rather than finished products.
Organizations may need to identify products containing per- and polyfluoroalkyl substances (PFAS), Hazardous Air Pollutants (HAPs), Extremely Hazardous Substances (EHSs), REACH Substances of Very High Concern (SVHCs) or substances with occupational exposure limits (OELs).
Trying to answer these questions by manually reviewing hundreds, or even thousands, of SDSs is both time-consuming and susceptible to human error.
Chemical ingredient indexing provides a more systematic approach by identifying individual constituents across an organization's chemical inventory and comparing them against applicable regulatory or organizational criteria.
The result is ingredient-level visibility that allows safety professionals to quickly answer important questions:
- Which products contain PFAS?
- Where are chemicals with occupational exposure limits used?
- Which ingredients appear across multiple facilities?
- Which chemicals may trigger new or emerging reporting requirements?
This visibility supports more proactive decision making, allowing organizations to identify potential issues before regulations change, reporting deadlines arrive or workplace exposures occur.
Container Labeling Deserves More Attention
As organizations prepare for HazCom 2024, employers should focus on workplace container labeling.
Most employers are familiar with supplier labels that arrive on shipped containers. However, OSHA's requirements extend beyond original containers.
Secondary containers, such as spray bottles or solvent cans used during daily operations, must also communicate hazard information effectively to employees.
This is often where compliance challenges emerge.
Secondary containers are frequently handwritten, inconsistently labeled or left unlabeled altogether. In some cases, labels become damaged or illegible over time. In others, abbreviated labels omit important hazard information that workers need to safely handle the material.
The consequences extend beyond regulatory compliance.
Workers rely on workplace labels to quickly recognize hazards, understand appropriate PPE, identify safe handling practices and respond appropriately if an exposure occurs. An inconsistent labeling system can create confusion precisely when clear communication matters most.
As employers update workplace HazCom programs during the HazCom 2024 transition, they should evaluate whether existing workplace labeling practices effectively communicate the hazards associated with transferred chemicals.
Compliance Depends on Connected Information
Chemical information becomes most valuable when it can support decisions across multiple safety and compliance activities.
For example, inventory and ingredient information can help organizations:
- Support Toxics Release Inventory (TRI) and Tier II reporting
- Evaluate whether storage or usage thresholds have been exceeded
- Identify opportunities to substitute less hazardous chemicals
- Support industrial hygiene sampling strategies
- Eliminate duplicate or obsolete chemical purchases
- Demonstrate chemical stewardship to customers and other stakeholders
Consider PFAS. As scientific understanding and regulatory activity surrounding PFAS continue to evolve, many organizations have found themselves needing to determine whether these substances exist anywhere within their operations. Companies in numerous industries have begun requesting information about PFAS from suppliers and business partners, making chemical transparency increasingly important from both a regulatory and business perspective.
Organizations with detailed ingredient visibility can often answer these questions more efficiently than those relying solely on manual SDS reviews.
The same principle applies to other emerging chemicals of concern. Regulatory priorities will continue to change over time. Organizations that understand their chemical inventories at the ingredient level are generally better positioned to respond when they do.
Preparing for What's Next
EHS teams may sometimes hyperfocus on regulatory requirements. As the 2026 EHS 360 Benchmark Report shows, 60% of EHS professionals reported the perception that regulatory complexity is increasing more quickly than they can adapt. Still, HazCom 2024 should not be viewed simply as another compliance deadline.
HazCom 2024 presents an opportunity for organizations to evaluate the maturity of their chemical management programs and make sure they include:
- A complete and current chemical inventory
- Ingredient-level visibility into chemicals of concern
- Consistent workplace container labeling
- A written Hazard Communication Program
- Employee training aligned with current hazards and workplace practices
- Processes for supporting ongoing regulatory reporting and emerging compliance obligations
As organizations grow, these responsibilities inevitably become more complex. More facilities, more suppliers, more products and evolving regulations increase the need for accurate, connected chemical information.
The Bottom Line: Protecting Your People
As you navigate the HazCom transition, have the right mindset. Chemical management is not ultimately about managing compliance. It's about protecting workers.
HazCom exists because workers need understandable information about the chemicals they use and the precautions necessary to protect themselves. Accurate inventories, accessible SDSs, effective workplace labels, written Hazard Communication programs and employee training work together to achieve that objective.
Employees cannot be trained effectively if workplace hazards have not been fully identified. Workplace labels cannot communicate hazards accurately if organizations lack complete chemical information. Written Hazard Communication programs become difficult to maintain when inventories are incomplete or outdated.
When chemical information is organized, current and consistently managed, everyone from frontline employees to supervisors, industrial hygienists and EHS leaders can make better-informed decisions.
The organizations best prepared for HazCom 2024, and for whatever regulatory changes come next, will be those treating chemical information not simply as documentation to maintain, but as a strategic resource for protecting workers, strengthening compliance and making better operational decisions.
This article originally appeared in the October 2026 issue of Occupational Health & Safety.