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.

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.

Every mature chemical management program begins with a complete and accurate chemical inventory.

This article originally appeared in the October 2026 issue of Occupational Health & Safety.

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