No. An SDS binder holds the sheets. A covered workplace also needs a written program. The program explains how you handle labels, SDS, and employee information and training. It also lists your hazardous chemicals.
Reviewed October 17, 2026
Give the program its own written explanation
A covered employer must develop, implement and maintain a written program at each workplace. It explains how you will meet the labeling, SDS, and employee information and training rules. §1910.1200(e)(1); subject to coverage in (b)
The program must list the known hazardous chemicals, using the product identifiers shown on the matching safety data sheets. §1910.1200(e)(1)(i)
It must also describe how you will tell employees about the hazards of non-routine tasks and about chemicals in unlabeled pipes in their work areas. §1910.1200(e)(1)(ii)
Name one person to keep the chemical list current. Describe how staff get the right information. Use your real chemical list, not a generic one that nobody has checked.
Check the people who share your site
Sometimes another employer's employees may be exposed. Then the written program must say how you will give that employer on-site SDS access, precautionary information and your workplace labeling-system information. §1910.1200(e)(2)(i)–(iii)
You must make the written program available on request to employees, their designated representatives and the officials the standard names. §1910.1200(e)(4)
Have your safety lead check which workplaces and employees are covered. Note where the written program sits in your office index. Keep it separate from the SDS collection.
Questions and answers
Can the manual just say the SDS are on file?
That is a start, not the program. Check whether your written program also explains the chemical list, warnings, information and training that apply to you.
About Bill Stomp
Bill Stomp built Propane Safety Pro. He is a war veteran who ran over 87 propane branch offices across 12 states, and he has helped more than 200 propane companies improve their profits, sales, safety and operations.
Next step
Pull your current chemical list. Then see the Policies & Procedures manual for propane companies and the written programs it should organize.
General information, not legal advice.