Direct comparison
SDS vs MSDS: What Changed, Still Valid?
SDS replaced MSDS under OSHA's 2012 GHS-aligned rule. What changed, whether legacy MSDS binders are still valid, and the 30-year 1910.1020 retention rule.
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How do MSDS (pre-2012), SDS (2012–present, GHS-aligned) compare side by side?
The table below compares MSDS (pre-2012), SDS (2012–present, GHS-aligned) across 10 procurement-relevant dimensions, from full name through must the document itself be retained 30 years?.
Side-by-side comparison
| Dimension | MSDS (pre-2012) | SDS (2012–present, GHS-aligned) |
|---|---|---|
| Full name | Material Safety Data Sheet | Safety Data Sheet |
| Format | Manufacturer-chosen layout; section count and order vary sheet to sheet | Fixed 16-section structure, same order, every manufacturer worldwide |
| Governing standard | Pre-2012 OSHA Hazard Communication Standard | 29 CFR 1910.1200, 2012 revision, aligned to UN GHS |
| Hazard classification | Manufacturer-specific hazard rating language, not standardized | Standardized GHS hazard classes and categories |
| Pictograms / signal words | Not standardized | Standardized GHS pictograms, Danger/Warning signal words |
| Manufacturer/importer/distributor compliance date | N/A — superseded format | June 1, 2015 (sell-through cutoff December 1, 2015) |
| Employer workplace-program update date | N/A | June 1, 2016 |
| Acceptable as your current hazard reference today? | No — replace with a current SDS from the manufacturer | Yes, if genuinely the manufacturer’s current version |
| Counts as an OSHA employee exposure record (29 CFR 1910.1020)? | Yes, if it indicates the material may pose a health hazard (1910.1020(c)(5)(iii)) | Yes — same status |
| Must the document itself be retained 30 years? | Not if chemical identity, location, and use period are captured elsewhere for 30 years (1910.1020(d)(1)(ii)(B)) | Same carve-out applies |
Common questions
Common questions about MSDS (pre-2012) vs SDS (2012–present, GHS-aligned)
Can I still use an old MSDS instead of a current SDS?
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Not as your operative hazard reference for a chemical still in use. OSHA expects the SDS on file to be the manufacturer’s current, GHS-aligned version. If you find an MSDS for a chemical that’s still in service, replace it with a current SDS — most manufacturers publish these on their own websites.
Do I have to keep old MSDSs on file for compliance?
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Not the physical document specifically. Under 29 CFR 1910.1020(d)(1)(ii)(B), MSDSs and other substance-identity records "need not be retained for any specified period" as long as the chemical’s identity, where it was used, and when it was used are captured in some other record kept for at least 30 years. Many EHS programs keep the original MSDS anyway because it’s the simplest way to satisfy that requirement.
How long must SDSs and MSDSs be retained under OSHA rules?
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It depends on what the document establishes, not its format. Employee exposure records generally must be kept at least 30 years (1910.1020(d)(1)(ii)); employee medical records for duration of employment plus 30 years (1910.1020(d)(1)(i)). An SDS/MSDS that indicates a chemical may pose a health hazard is defined as an exposure record under 1910.1020(c)(5)(iii), so it can carry that 30-year duty.
Is a GHS-formatted SDS legally required today?
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Yes. OSHA’s Hazard Communication Standard, 29 CFR 1910.1200, has required the 16-section GHS-aligned SDS format since the transition completed in 2015–2016. Chemical manufacturers, importers, and distributors have been required to ship products with the new-format SDS since June 1, 2015.
What if a supplier still sends an MSDS instead of an SDS?
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Request the current SDS directly — most manufacturers maintain SDS libraries on their websites even if a shipment paperwork lag produced an outdated document. Don’t substitute an MSDS for a missing SDS in your hazard communication program; note the gap and follow up.
