Recently, we received a question regarding whether safety data sheets (SDSs) are required under OSHA’s hazard communication standard (29 CFR 1910.1200) for items such as drill bits. See what we had to say.
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Question: Are we required to have an SDS on packaged power tool supplies, i.e., drill bits, cutters, taps, etc.?
Answer: These items may be exempt from the hazard communication standard, or HazCom (29 CFR 1910.1200), under the following conditions:
If they are considered “articles” (as defined in 29 CFR 1910.1200(c)). An “article” means a manufactured item: (1) which is formed to a specific shape or design during manufacture (2) which has end use function(s) dependent in whole or in part upon its shape or design during end use; and (3) which does not release, or otherwise result in exposure to, a hazardous chemical under normal conditions of use. Any product that meets the definition of an “article,” would be exempt from the requirements of HazCom. This OSHA letter of interpretation discusses drill bits as an “article.”
Basically, if your tool supplies do not potentially release chemicals during normal operating conditions, they would be considered an article exempt from HazCom’s requirements. However, if chemicals were released during normal operating conditions, you would need an SDS.