SDS - Safety Data Sheets - how often are they required to be reviewed?
In a SQF food manufacturing facility, also regulated by OSHA of course, document policy is that they are reviewed annually. However, some vendors of our ingredients and/or chemicals, etc. are submitting SDS' that are valid within the 3 year OSHA requirement, but not our annual requirement. Is it a general rule that SDS' are okay if they are marked reviewed within the last 3 years?
In principle, each batch of such materials have to include SDSs, TDSs (technical data sheet) and COAs (or equiv.) in every delivery. However, there is no need to send SDSs & TDSs several times when many batches have the same sheets. For SDSs, they have to be updated whenever regulations changes (Section 15) or new scientific information is published (likely Section 2, 11, 12 & 13).
Annual review is good to avoid noncompliance by outdated SDSs.
I would anticipate that most auditors will expect a minimum frequency of annually in the absence of a specific Standard /regulatory requirement.
My company reviews our SDS sheets annually - but this is just against our inventory list to ensure that we catch any outdated or missed SDS's.
We do not have it documented in our policy that we have to review them annually. And I don't think SQF has a required frequency for reviewing SDS sheets - they don't explicitly say you have to review them once a year right? [Or if so, what page?]