Do Safety Data Sheets Expire?

Short answer: no. A safety data sheet has no expiry date, and 29 CFR 1910.1200 sets no review interval — the words “expire”, “expiration” and “three years” do not appear anywhere in the section. What the standard does impose is a three-month duty on whoever prepares the sheet, and a standing duty on you to hold the sheet that is current. Those are different obligations, and mixing them up is why so many binders get rebuilt for no reason.

The detail that decides it — the only deadline the standard actually contains, where the three-year rule people remember comes from, and how to tell whether the sheet in your binder is the current one — is set out below.

1. The only deadline in the standard

29 CFR 1910.1200(g)(5) puts the clock on the preparer, not on the sheet:

“If the chemical manufacturer, importer or employer preparing the safety data sheet becomes newly aware of any significant information regarding the hazards of a chemical, or ways to protect against the hazards, this new information shall be added to the safety data sheet within three months.”

Read that carefully, because it is narrower than it looks. The three months start from becoming newly aware of significant information, not from any calendar date. A chemical whose hazards have not changed can sit for years with a sheet that is entirely correct and entirely compliant. The same paragraph adds that if the chemical is not currently being produced or imported, the information must be added before it is introduced into the workplace again.

2. So where does the “three-year rule” come from?

Not from this standard. Search 1910.1200 and you will not find an expiry, an expiration, a review period, or the phrase “three years” anywhere in it — including the appendices. If someone has told you your sheets go stale on a fixed schedule, ask them which paragraph says so.

The rule of thumb is not useless, though. A sheet that is many years old is worth checking, because you cannot tell from the sheet itself whether the manufacturer has since learned something new. Checking is prudence. Discarding a sheet because of its age alone is not a legal requirement, and re-collecting a whole binder on that basis is work the standard never asked for.

3. What you are actually required to hold

Three duties sit on the employer, and none of them mentions a date:

29 CFR 1910.1200(g)(1) — employers “shall have a safety data sheet in the workplace for each hazardous chemical which they use”.
29 CFR 1910.1200(g)(8) — those sheets must be maintained in the workplace and readily accessible during each work shift to employees in their work areas.
29 CFR 1910.1200(g)(6)(iii) — if a sheet did not arrive with a shipment labelled as a hazardous chemical, the employer must obtain one from the manufacturer or importer as soon as possible.

Put together, the obligation is to hold the safety data sheet for the product — which in practice means the current one, because that is the one the manufacturer will give you if you ask. See do you have to pay for safety data sheets?; asking costs nothing, and (g)(6)(iv) obliges them to answer.

4. Updates are supposed to come to you

You are not meant to poll every supplier forever. Under 29 CFR 1910.1200(g)(6)(i), chemical manufacturers and importers must ensure that distributors and employers are provided an appropriate safety data sheet with their initial shipment, and with the first shipment after a safety data sheet is updated. Distributors carry the same duty down the chain under (g)(7)(i).

That is the mechanism the standard relies on: when a sheet changes, the next delivery brings the new one. It works well for products you buy regularly. It does nothing at all for the drum you bought once in 2021 and still have — which is exactly where an old sheet is most likely to be out of date, and the case worth a five-minute check.

5. How to tell whether your copy is the current one

The sheet itself gives you one clue and only one. Section 16, “Other information”, must include the date of preparation or last revision — that is 1910.1200(g)(2)(xvi), and it is the only date the format guarantees. Compare it against the sheet the manufacturer publishes today:

Note the product identifier from the label and the revision date in Section 16 of your copy.
Pull the manufacturer’s current sheet from their website, or request it under (g)(6)(iv).
If the revision dates match, yours is current — regardless of how old it is.
If theirs is newer, replace yours, and check Section 2 to see whether the classification changed. A changed hazard classification is the case that also touches your labels and your training.

Number 4 is the one that matters beyond the binder. If a product’s classification changed, your secondary-container labels and what your people were told about it may both be out of date — see GHS secondary container labels and HazCom training requirements.

6. Expiry is a different question from retention

“Do sheets expire?” and “how long must I keep them?” get answered together and should not be. A sheet you no longer use does not expire — but under 29 CFR 1910.1020 the record of which hazardous chemicals your employees were exposed to, and when, carries its own long retention period. That is a records-access obligation, not a HazCom one, and it is why deleting superseded sheets can be the wrong move. See how long you must keep safety data sheets.

7. A practical policy that is defensible

Do not discard or re-request sheets on an age schedule. No paragraph requires it.
Do replace a sheet whenever a new one arrives with a shipment — that is the standard’s own update mechanism working.
Do check the products you no longer buy regularly, since nothing will push an update to you for those.
Do re-check anything whose Section 2 classification you rely on for labels, PPE or training decisions.
Do keep the superseded copy rather than destroying it, for the reason in section 6 above.

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Frequently asked questions

Do safety data sheets expire?

No. There is no expiry date on a safety data sheet, and 29 CFR 1910.1200 contains no review interval — the words expire, expiration and expiry do not appear in the section at all. The only deadline it contains is in (g)(5): when the party preparing the sheet becomes newly aware of significant information about the chemical's hazards, or ways to protect against them, that information must be added within three months.

Is there a three-year rule for safety data sheets?

Not in 29 CFR 1910.1200. Search the section, appendices included, and you will find no expiry, no review period and no reference to three years. Checking an old sheet against the manufacturer's current version is prudent, but discarding sheets on an age schedule is not something the standard requires.

How do I know if my safety data sheet is the current one?

Section 16 of the sheet must include the date of preparation or last revision — that is 1910.1200(g)(2)(xvi), and it is the only date the format guarantees. Compare it with the sheet the manufacturer publishes today, or request the current one under (g)(6)(iv). If the revision dates match, your copy is current no matter how old it is.

Who is supposed to send me an updated safety data sheet?

The supplier. Under 1910.1200(g)(6)(i), chemical manufacturers and importers must ensure that distributors and employers are provided an appropriate safety data sheet with their initial shipment and with the first shipment after the sheet is updated; distributors carry the same duty under (g)(7)(i). That mechanism only reaches products you still buy, so anything you no longer order regularly is worth checking yourself.

Should I throw away an old safety data sheet once I have the new one?

Be careful. HazCom does not require you to keep superseded sheets, but 29 CFR 1910.1020 governs records of employee exposure to hazardous substances and carries its own long retention period. Expiry and retention are separate questions, and destroying old sheets can be the wrong move.

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