What Are US SDS Translation Requirements Under OSHA HazCom?
Under OSHA’s Hazard Communication Standard, a safety data sheet (SDS) used in the United States must be in English. Translations into other languages are permitted and are not mandated. The English SDS must keep all 16 required sections in the prescribed order. A translation supports worker training and hazard recognition. It does not replace the English SDS. Source: 29 CFR 1910.1200.
Table of Contents
What is the scope of SDS translation requirements in the United States?
The federal rule is 29 CFR 1910.1200, the OSHA Hazard Communication Standard (HCS). Paragraph (g)(2) states that the chemical manufacturer or importer shall ensure that the SDS is in English. The same paragraph states that the employer may maintain copies in other languages as well. Source: 29 CFR 1910.1200.
OSHA publication 3514 repeats the point. The information in the SDS must be in English, although it may also appear in other languages. Source: OSHA 3514, Hazard Communication Standard: Safety Data Sheets.
Definition of an SDS translation
An SDS translation is a faithful rendering of an English SDS into another language. It keeps the section structure, hazard classification, hazard statements, precautionary statements, numeric values and units of the source document. The English SDS remains the controlling document.
What the rule does not require
The HCS does not require an employer to hold a translated SDS. OSHA’s 1998 inspection directive explains that the English requirement exists to prevent importers from supplying SDSs only in a foreign language. It states that the requirement does not prevent a manufacturer or employer from translating SDSs into foreign languages to help non-English-speaking employees with training comprehension and hazard recognition. Source: OSHA CPL 02-02-038.
The same logic applies to labels. OSHA’s 1988 interpretation states that an employer may add label information in a language other than English under 29 CFR 1910.1200(f)(9). There is no requirement to do so, as long as the information is also presented in English. Source: OSHA interpretation of February 24, 1988.
Who is responsible for the SDS
Chemical manufacturers and importers must obtain or develop an SDS for each hazardous chemical they produce or import. Employers must have an SDS in the workplace for each hazardous chemical they use. Source: 29 CFR 1910.1200(g)(1).
The party that prepares the SDS must ensure that the information accurately reflects the scientific evidence used in the hazard classification. New significant hazard information must be added to the SDS within three months of the preparer becoming aware of it. Source: 29 CFR 1910.1200(g)(5).
OSHA’s 2009 GHS interpretation states that employers are not held responsible for inaccurate information on an SDS they did not prepare and accepted in good faith. The responsible party named on the document is accountable for accuracy. Source: OSHA interpretation of October 6, 2009.
What must an SDS translation preserve?
An SDS must include at least 16 section numbers and headings in the order listed in 29 CFR 1910.1200(g)(2). A translation must keep the same numbering and order. Source: 29 CFR 1910.1200.
Section | Heading |
1 | Identification |
2 | Hazard(s) identification |
3 | Composition/information on ingredients |
4 | First-aid measures |
5 | Fire-fighting measures |
6 | Accidental release measures |
7 | Handling and storage |
8 | Exposure controls/personal protection |
9 | Physical and chemical properties |
10 | Stability and reactivity |
11 | Toxicological information |
12 | Ecological information |
13 | Disposal considerations |
14 | Transport information |
15 | Regulatory information |
16 | Other information, including date of preparation or last revision |
Appendix D to the standard specifies the information to be included under each heading. Source: OSHA 3514.
Elements that need controlled handling
Signal words, hazard statements and precautionary statements. Use approved terminology and keep a glossary.
Section 1 contact data. OSHA’s 2018 interpretation states that the responsible party address must be in the United States and the phone number must be a domestic number. A translation must not alter these entries. Source: OSHA interpretation of September 18, 2018.
Chemical names, CAS numbers, concentration ranges, exposure limits and units. These are copied, not reworded.
The Section 16 revision date. The translation must show which English revision it follows.
What steps produce a compliant SDS translation workflow?
Each step has an owner and a control. The owner is a role, not a person.
Confirm the English SDS is current. Owner: the responsible party or EHS lead. Control: version check against the Section 16 revision date and the supplier’s latest issue. OSHA’s guide states that employers must keep the current version and make a newly received SDS available. Source: OSHA 3695, Small Entity Compliance Guide.
Decide which languages are needed. Owner: EHS lead with HR. Control: a roster of the languages workers read, reviewed when staffing changes.
Freeze terminology. Owner: localization manager. Control: a term base for hazard and precautionary statements, approved by a subject-matter reviewer.
Translate. Owner: language service provider. Control: a documented process with translator qualification records and tracked changes.
Review technically. Owner: a qualified chemist, toxicologist or industrial hygienist. Control: signed review record covering Sections 2, 4, 8, 9, 11 and 14.
Run quality assurance. Owner: language service provider QA lead. Control: automated checks for numbers, units, CAS numbers and section order, plus a bilingual comparison.
Label the translation. Owner: document control. Control: header stating that the English SDS is the controlling version and giving its revision date.
Distribute and store. Owner: EHS lead. Control: access control by site and role, plus an audit trail of who published and who retrieved each version.
Retire superseded versions. Owner: document control. Control: archive with revision history so inspectors and auditors can trace changes.
How must SDSs be accessible to workers?
Under 29 CFR 1910.1200(g)(8), the employer must keep SDS copies in the workplace for each hazardous chemical. They must be readily accessible during each work shift when employees are in their work areas. Source: 29 CFR 1910.1200.
OSHA allows electronic access. It requires an adequate back-up system for power outages, equipment failure or other emergencies. Workers must be trained on the system and able to obtain hard copies. In a medical emergency, hard copy SDSs must be immediately available to medical personnel. Source: 29 CFR 1910.1200.
OSHA’s small entity guide notes that employers decide what suits their workplace. Some keep a binder in a central location and others provide electronic access. Workers and medical personnel must be able to get the information immediately in an emergency. Source: OSHA 3695.
Electronic distribution by suppliers
OSHA’s 2013 interpretation on electronic SDS distribution states that manufacturers must confirm downstream users have agreed to electronic access. They cannot require users to buy new technology. They must give positive, verifiable notice with access information and must notify users when an SDS is updated. All SDSs must be provided at no cost. Source: OSHA interpretation of May 13, 2013.
Translated copies should follow the same access control as the English SDS. A worker who reads Spanish, for example, should reach the Spanish copy and the English SDS from the same location.
How should employers serve workers who do not read English?
OSHA’s small entity guide states that employers with workers who speak other languages may be able to obtain SDSs in those languages to support effective hazard communication. Source: OSHA 3695.
The training duty is the practical driver. Employees must receive information they are able to understand, so a translated SDS often sits inside a wider program of translated training material and workplace notices. The translation does not change the legal status of the English SDS.
What decision criteria apply when choosing translation scope and vendor?
Criterion | Question to answer | Control to verify |
Language coverage | Which languages do workers read, including regional variants? | Written language roster |
Subject expertise | Is the reviewer qualified in chemistry or toxicology? | Reviewer credentials on file |
Terminology governance | Are hazard and precautionary statements managed in a term base? | Approved glossary, change log |
Data security | Where are SDS files processed and stored? | Hosting location, information security certification, access control |
Quality system | Is there a recognized translation standard? | Certification such as ISO 17100 |
Traceability | Can each translation be tied to an English revision? | Version header, audit trail |
Update speed | How quickly can a revised SDS be re-issued in each language? | Stated turnaround, translation memory reuse |
Teams that also manage laboratory or manufacturing records can compare GLP and GMP record requirements when they set document formats for regulated files.
Use of automated translation
Raw machine output is not a reviewed translation. A workflow that combines AI output with human subject-matter review needs documented review, because SDS content affects safety decisions. Reviewed output, not unreviewed output, is what a worker should receive.
What examples show how the requirements apply?
Example 1: Manufacturer with Spanish-speaking line workers
A US plant receives English SDSs from suppliers. It commissions Spanish copies of the SDSs for its 40 most-used chemicals. The English SDS stays in the binder and the electronic system. Spanish copies sit beside each English SDS. The Spanish copies carry a header naming the English revision date. The plant meets the English requirement and supports training comprehension.
Example 2: Importer bringing in a product with a foreign-language SDS
An importer receives a product with an SDS in a foreign language only. Under 29 CFR 1910.1200(g)(2), the importer must ensure that an English SDS exists. The foreign-language document alone does not satisfy the standard. Source: OSHA CPL 02-02-038.
Example 3: Product labeled under EU GHS requirements
OSHA’s 2009 interpretation states that it would not cite manufacturers, importers or distributors marketing products labeled under EU GHS requirements, provided the label and other warnings include the information required by the HCS. The condition is HCS content, so an EU document is checked against Appendix D before use. Source: OSHA interpretation of October 6, 2009.
How do the 2024 HCS update dates affect translated SDSs?
OSHA’s final rule was published May 20, 2024 and took effect July 19, 2024. It aligns the HCS primarily with GHS Revision 7. Source: OSHA HCS rulemaking page.
Appendix D updates include revisions to SDS Sections 2, 3, 9 and 11. Source: OSHA HCS 2024 Q&A.
On January 15, 2026, OSHA extended the compliance dates. The substance deadline moved from January 19, 2026 to May 19, 2026. Other dates moved by four months. Source: OSHA compliance date extension notice. The Q&A document lists the mixtures deadline as November 19, 2027. Source: OSHA HCS 2024 Q&A.
The substance date has passed. Translated SDSs for substances should now follow the updated English revision. Translations of mixture SDSs should be planned against the 2027 date. Confirm current dates on OSHA’s page before scheduling work.
Difference from EU rules
EU rules require SDSs in an official language of the country where the product is placed on the market. US rules require English and allow other languages. A company that sells in both markets needs the English SDS for the US and a national-language SDS for each EU market. This comparison is general. Verify current REACH and CLP text with EU authorities before relying on it [VERIFY].
What are common failure modes and mitigations?
Failure mode | Effect | Mitigation |
Translation not tied to an English revision | Workers read outdated hazard data | Version header, update trigger when Section 16 date changes |
Inconsistent hazard statement wording | Confusion across chemicals and sites | Term base with approved statements |
Altered numbers or units | Wrong exposure or storage instructions | Automated QA for numbers, units, CAS numbers |
Section order changed | Document no longer follows the standard layout | Section order check in QA |
Translation stored without access control | Uncontrolled copies in circulation | Role-based access, audit trail, single repository |
Electronic system fails | Workers cannot reach SDSs | Back-up system, hard copies, worker training on the system |
SDS content left unchanged after new hazard data | Out-of-date SDS in all languages | Three-month update rule, re-translation of changed sections |
Translation viewed as the legal SDS | English version missing in the file | Policy that the English SDS is the controlling document |
Perspective
We treat SDS translation as controlled safety documentation, not as general text conversion. The English SDS carries the legal weight under OSHA. The translation carries the training and comprehension value for the worker. That distinction shapes how we work. We use an AI+HUMAN hybrid process in which subject-matter experts review every translation. Terminology from a client’s term bases and translation memories is applied so that hazard and precautionary statements stay consistent across revisions. Our LangOps System runs on EU-hosted infrastructure, and our ISO 27001 and ISO 42001 certifications cover information security and AI use and safety. Our view is that a translated SDS should always show which English revision it follows, and that revision changes should trigger re-translation of the affected sections. With the HCS 2024 update changing Sections 2, 3, 9 and 11, that discipline matters for every language a company maintains. Eric Brown
Where does AD VERBUM fit?
AD VERBUM provides AI+HUMAN hybrid translation for technical, legal and medical documentation in 150+ languages, with subject-matter expert review and QA aligned to ISO 17100 and ISO 18587. Its LangOps System is hosted on EU servers and integrates client translation memories and term bases. Certifications are audited by Bureau Veritas. Project scope and pricing are set by quote. See the translation and localization services.
Key points
The SDS used in the US must be in English under 29 CFR 1910.1200(g)(2).
Translations into other languages are allowed and are not required.
A translation keeps all 16 sections in the prescribed order.
The English SDS is the controlling document, and each translation names its revision.
Employers keep SDSs readily accessible during each shift, with a back-up if access is electronic.
Manufacturers and importers prepare the SDS and update it within three months of new hazard information.
The HCS 2024 update changes Sections 2, 3, 9 and 11. The substance deadline was May 19, 2026, and the mixtures deadline is November 19, 2027.
Controls for translation are access control, audit trail, terminology governance and QA.
FAQ
Does OSHA require SDSs in Spanish?
No. OSHA requires the SDS to be in English. Employers may keep copies in other languages, and OSHA’s guidance says employers with non-English-speaking workers may obtain SDSs in those languages to support hazard communication. Source: OSHA 3695.
Can a translated SDS replace the English SDS?
No. The manufacturer or importer must ensure the SDS is in English. A translation is an addition that supports worker training and hazard recognition. Source: OSHA CPL 02-02-038.
Who pays for a translated SDS?
The HCS does not assign translation costs. OSHA states that SDSs from manufacturers must be provided at no cost, which refers to the English SDS and its delivery. Translation cost is a business decision for the employer. Source: OSHA interpretation of May 13, 2013.
Do translated labels need English as well?
Yes. An employer may add label information in another language, but the information must also appear in English. Source: OSHA interpretation of February 24, 1988.
Sources
OSHA 3514, Hazard Communication Standard: Safety Data Sheets
OSHA CPL 02-02-038, Inspection Procedures for the Hazard Communication Standard
OSHA interpretation, September 18, 2018, SDS responsible party
OSHA interpretation, May 13, 2013, electronic distribution of SDSs
OSHA interpretation, February 24, 1988, labels in other languages