HazCom/GHS – Electronic SDS

• The manufacturer must ensure that the downstream user has agreed to this type of information access, (“opt-in”).
• The manufacturer cannot require the downstream user to purchase new technology in order to obtain the SDS.
• The manufacturer must ensure that some positive and verifiable form of notification (such as a letter or email) is provided with all the information necessary to access the SDS(s).
• The manufacturer must ensure that some positive and verifiable form of notification is provided to ensure that the downstream user is aware when SDSs are updated.

Electronic Distribution of SDS – OSHA Compliance Interpretation