The Job Ended. Who Can Still Ask for Your SDS?

No OSHA standard tells you to revoke anyone's access when a job ends. What the standards do say is the part most closeout checklists miss: a safety data sheet is an exposure record, the definition of employee includes people who no longer work for you, and a records request starts a fifteen-working-day clock to answer or explain the delay.

OSHA has no rule requiring an employer to withdraw access to safety data sheets when a project ends. Under 29 CFR 1910.1200(g)(8), sheets must be readily accessible during each work shift to employees in their work areas. After the work ends, 29 CFR 1910.1020 takes over: a safety data sheet is an employee exposure record, employee includes a former employee, employer includes a former employer, and if access cannot reasonably be provided within fifteen working days the employer must, within those same days, give the reason for the delay and the earliest date the record can be made available.

The last trailer pulls out

A mechanical sub finishes a tenant fit-out on a Friday. Two pallets of adhesive, sealant, and a solvent-based primer go back on the truck. On Monday the general contractor's project engineer works down the closeout list: as-builts filed, punch list signed, badges collected, jobsite portal logins disabled.

That last item feels like housekeeping. Eighteen months later a former helper from that sub files a workers' compensation claim for a respiratory condition and asks, through his union, for the chemical records covering the weeks he worked in that building. The portal is off. The sub has changed accounting systems. Nobody wrote down which primer was used on which floor.

The compliance question was never who to shut off. It was whether the information can still be produced.

What OSHA requires while the crew is on site

The one everybody quotes is the access duty. 29 CFR 1910.1200(g)(8) requires the employer to "maintain in the workplace copies of the required safety data sheets for each hazardous chemical" and to "ensure that they are readily accessible during each work shift to employees when they are in their work area(s)." The same paragraph settles the electronic question in a parenthesis: "Electronic access and other alternatives to maintaining paper copies of the safety data sheets are permitted as long as no barriers to immediate employee access in each workplace are created by such options."

The one that governs a jobsite with more than one employer on it is separate. Paragraph (e)(2) applies to "Employers who produce, use, or store hazardous chemicals at a workplace in such a way that the employees of other employer(s) may be exposed (for example, employees of a construction contractor working on-site)." Those employers must build into the written program "the methods the employer will use to provide the other employer(s) on-site access to safety data sheets for each hazardous chemical the other employer(s)' employees may be exposed to while working."

Construction does not get a lighter version. 29 CFR 1926.59 is one sentence: "The requirements applicable to construction work under this section are identical to those set forth at § 1910.1200 of this chapter."

OSHA applied all of this to the shared-binder arrangement in a May 16, 1990 interpretation letter answering a plumbing and mechanical contractors' association. If sheets live in one central location, the agency wrote, "the method must also provide for access to them at all times employees are working on the site." And the duty does not transfer with the paperwork: "Each contractor has a responsibility to ensure that his employees have ready access to MSDSs for each hazardous chemical in the workplace during each work shift. If a contractor relies on another employer to maintain his MSDSs, and the MSDSs are unavailable to that contractor's employees, the contractor could be cited under [1910.1200(g)(8)], unless it is determined that he has a legitimate defense to a citation." The letter carries an August 23, 2004 correction noting that the multi-employer citation section of the Field Operations Manual was superseded by CPL 02-00-124.

Read those together and the boundary is clear: paragraph (g)(8) is about people in a work area during a shift. When the shift stops, that paragraph stops with it.

Does 1910.1020 still apply after the job ends?

A second standard picks up where the first one ends, and construction is inside it by the same one-sentence device. 29 CFR 1926.33: "The requirements applicable to construction work under this section are identical to those set forth at § 1910.1020 of this chapter." Both cross-references were written by the June 20, 1996 consolidation rule.

29 CFR 1910.1020 applies, in its own words, "to each general industry, maritime, and construction employer who makes, maintains, contracts for, or has access to employee exposure or medical records." Then it defines its two nouns in a way that makes the closeout question fall apart:

Demobilizing a crew changes the job. It does not change either definition. The helper who left eighteen months ago is still an employee for the purpose of this standard, and the sub that no longer works for the general contractor is still an employer for the purpose of this standard.

Your safety data sheet is an exposure record

This is the hinge, and it is the part that surprises people who have read 1910.1200 carefully and never read 1910.1020. Among the things that count as an employee exposure record, paragraph (c)(5)(iii) lists: "Material safety data sheets indicating that the material may pose a hazard to human health."

The retention rule that follows is more forgiving than its reputation, and more demanding than a shredder. Exposure records run thirty years under (d)(1)(ii), with an exception written for sheets specifically. Under (d)(1)(ii)(B), safety data sheets "need not be retained for any specified period as long as some record of the identity (chemical name if known) of the substance or agent, where it was used, and when it was used is retained for at least thirty (30) years." A footnote to that paragraph adds that sheets "must be kept for those chemicals currently in use that are effected by the Hazard Communication Standard in accordance with 29 CFR 1910.1200(g)."

Three fields survive the job by thirty years: what the chemical was, where it was used, when it was used. Not the PDF. The trail. Our 30-year retention guide works through the full table and the exceptions; what matters at closeout is that deleting a project from a system can quietly delete the where and the when while everyone assumes the sheet in the vendor's library is the record.

Who can ask, and how long you have

Once the sheet is an exposure record, the access rules of 1910.1020 attach to it. Paragraph (e)(2)(i)(A) is the operative sentence, and it opens with its own limit: "Except as limited by paragraph (f) of this section, each employer shall, upon request, assure the access to each employee and designated representative to employee exposure records relevant to the employee." Paragraph (f) is the trade-secret route, and it is a limit on how a specific chemical identity is disclosed, not a reason to refuse the record. Access itself is defined in (c)(1) as "the right and opportunity to examine and copy."

A designated representative under (c)(3) is "any individual or organization to whom an employee gives written authorization to exercise a right of access." The same paragraph adds a point that matters on union work: for exposure records, "a recognized or certified collective bargaining agent shall be treated automatically as a designated representative without regard to written employee authorization." When a representative asks without the employee's consent, (e)(2)(i)(B) requires the request to be in writing and to "specify with reasonable particularity" the records sought.

Then the clock. Paragraph (e)(1)(i):

"Whenever an employee or designated representative requests access to a record, the employer shall assure that access is provided in a reasonable time, place, and manner. If the employer cannot reasonably provide access to the record within fifteen (15) working days, the employer shall within the fifteen (15) working days apprise the employee or designated representative requesting the record of the reason for the delay and the earliest date when the record can be made available."

Fifteen working days is not a deadline to hand over the file. It is a deadline to either hand it over or account for the delay and name a date. The rule does not say that account has to be in writing, and neither should we. Both outcomes require knowing what you have.

Hazard communication points at this section directly. 1910.1200(g)(11): safety data sheets "shall also be made readily available, upon request, to designated representatives, the Assistant Secretary, and the Director, in accordance with the requirements of § 1910.1020(e)." The two standards are not parallel tracks. One hands off to the other.

Medical records follow a stricter route and should not be lumped in with exposure records at closeout. A designated representative reaching for those needs the specific written consent described in (c)(12), which has seven required contents and, under (c)(12)(ii), "does not operate for more than one year from the date of written authorization." The same paragraph adds that an authorization does not cover medical information that did not exist on the date it was signed "unless the release of future information is expressly authorized," and (c)(12)(iii) lets the employee revoke it in writing, prospectively, at any time.

What OSHA does not require

Say this part as plainly as the rest, because the compliance market rarely does.

• No revocation duty. Nothing in 1910.1200 or 1910.1020 requires an employer to withdraw, expire, or disable anyone's access when work ends. Turning off a portal login at closeout is a contract and data-security decision. It is a reasonable one. It is not a citation you are avoiding, and writing it into a program as though OSHA demanded it puts an invented rule in your own binder. Read both standards end to end and the word revoke appears exactly once, in 1910.1020(c)(12)(iii), where it is the employee who may revoke a medical-release authorization "in writing prospectively at any time." The revocation the rules contemplate runs the other way from the one on your closeout list.
• No format mandate. Under 1910.1020(d)(2), "Nothing in this section is intended to mandate the form, manner, or process by which an employer preserves a record as long as the information contained in the record is preserved and retrievable," with chest X-ray films the stated exception.
• No annual notice to people who left. The yearly information duty in (g)(1) runs to "current employees covered by this section." Former employees keep the right to ask; they do not have to be reminded of it.

And one duty that surfaces only when a company winds down, which is where subcontractor records go missing most often. Paragraph (h)(1): "Whenever an employer is ceasing to do business, the employer shall transfer all records subject to this section to the successor employer. The successor employer shall receive and maintain these records."

A closeout list that matches the text

The pattern is the same in every row: the obligations that outlive a project are about retrieval, and the ones people spend closeout time on are about cutoff. When the person leaving is your own employee rather than a subcontractor's crew, the same rights attach to that person by name; that checklist is here.

Keeping the three fields alive after the job

A tool cannot make this compliant on its own. What it can do is keep the three surviving fields from evaporating when a project closes.

In HazComFast, a chemical can be assigned to the jobsites where it is actually used, one at a time or in bulk, and every chemical row carries the date it was added. That is the where and the when of (d)(1)(ii)(B), held next to the what instead of in someone's memory. A safety data sheet uploaded into the app is stored in your organization's own private storage and served through expiring links, so the sheet on file is the one your crew was working from. Links shared outside the organization expire, which is the right default for security and, on the evidence above, has nothing to do with your OSHA obligation.

Two limits worth stating, because a tool that oversells here is worse than no tool. The jobsite assignment is something you do, not something that happens by itself: a chemical added without being assigned carries no location. And the app accepts a link to a manufacturer's sheet as well as an uploaded file, so the copy you control is the one you uploaded.

None of that answers the records request for you. It means that when the request arrives eighteen months later, the answer takes an afternoon instead of a forensic reconstruction of who bought what.

The question worth asking at closeout

Not who still has access. Ask instead: if someone who worked this job asks in three years what they were exposed to, can we say what it was, where it was used, and when? If the answer is yes, the portal login is a detail. If the answer is no, no amount of access control fixes it.

Further reading on the surrounding rules: our guides to SDS accessibility on the jobsite, closing gaps in an SDS library, and HazCom on multi-employer construction sites.

Regulatory text verified against the eCFR edition of August 31, 2026 (current as of September 1, 2026), consulted September 3, 2026. The interpretation letter was read in full at osha.gov the same day. This article is general information, not legal advice.