Safety data sheets: what to keep on file and where

Safety data sheets, usually shortened to SDS, are the document every hazardous cleaning product should arrive with — supplied by the manufacturer, setting out what the substance is, how it should be handled, what to do if something goes wrong. They're also one of the first things a client auditor or an HSE inspector will ask to see, which makes them a strange thing for so many contractors to treat as an afterthought.

Why the folder drifts out of date

The problem is rarely that nobody has an SDS folder. It's that the folder was assembled correctly at some point in the past and hasn't kept pace with what's actually happened since — a supplier changed, a product was reformulated, a site started using something new that a supervisor picked up locally without telling anyone in the office. Each of those is a small, reasonable decision on its own. Together, over a year or two, they produce a file that looks thorough and is quietly wrong in three or four places.

What should actually be on site

The practical standard is simple to state and harder to maintain: every hazardous product currently in use or storage on a site should have a matching, current SDS accessible on that site — not just at head office, and not a version for a product that's since been discontinued. This matters most for anything involved in chemical mixing risk, where the SDS is often the only place the specific incompatibility warning is written down.

Building it into the COSHH assessment

An SDS on its own isn't the compliance requirement — it's the input to one. The COSHH assessment sits on top of it, translating the manufacturer's generic hazard information into how that specific product is actually going to be used, stored and controlled on that specific site. A current SDS with no assessment behind it is only half the job; an assessment built on an outdated SDS is arguably worse, because it looks complete.

A simple review trigger

Rather than a calendar-based review that gets pushed back when things are busy, the more reliable trigger is tying the SDS check to any change: a new product ordered, a supplier switched, a site starting to use something it didn't before. Whoever approves the purchase or the substitution should also be the one who confirms the SDS is on file before the product reaches site, not after an auditor asks for it.

• –Match every SDS on site to a product that's actually currently in use — remove anything for a discontinued or replaced chemical
• –Keep SDS accessible on the site itself, not only in a central office folder nobody on shift can reach quickly
• –Trigger a review whenever a product or supplier changes, rather than relying on an annual calendar check
• –Cross-reference the SDS against the COSHH assessment for that substance so the two documents actually agree with each other
• –Check the manufacturer's own version number or issue date — an SDS can be reprinted without the underlying hazard information changing, but it can also change substantively without an obvious flag

What this looks like on a real contract

A contractor holding eleven sites changes washroom descaler in the spring — a like-for-like swap, same supplier, marginally cheaper. The new product's sheet goes into the folder at head office. Nine months later a client's auditor pulls the folder at one site, finds the sheet for the discontinued product still in the plastic wallet, and asks the cleaner on duty what she'd do if it went in her eyes. She answers from the old sheet, because that is the one on the wall. Nothing was hidden and nobody was careless: the product changed centrally and the paperwork at the eleven points of use did not.

The fix is unglamorous. A product change is not finished when purchasing switches supplier; it is finished when every site holding that product has the current sheet and the people using it have been told what changed. Treating the swap as a procurement event rather than an operational one is what opens the gap.

Common mistakes

• –Holding one master folder at head office and assuming the site copies match it
• –Filing the new sheet without removing the superseded one, so both sit in the wallet
• –Treating a like-for-like product swap as too minor to need a re-brief
• –Keeping sheets only in a system staff cannot reach from the cupboard where the product is
• –Letting the folder become an audit prop rather than something anybody reads
• –Assuming a supplier's catalogue is current — sheets are revised between catalogue printings