Common OSHA 29 CFR 1910 Mistakes That Trip Up Importers

Shipping a product into the United States is not the end of your compliance work if that product ends up in a workplace. [OSHA 29 CFR 1910](/regulations/osha-29cfr) covers the chemicals, materials, and equipment your buyers' employees will handle, and it puts obligations on anyone in the supply chain who provides hazard information. Here are the mistakes that most often cause problems for small importers and resellers.

Mistake 1: Assuming OSHA 29 CFR 1910 only applies to US manufacturers

Many importers believe this standard is someone else's problem because they don't operate the factory floor. But if your product contains a hazardous chemical and is used in a US workplace, the people putting it into use need proper hazard communication. Treat OSHA 29 CFR 1910 requirements as part of your import checklist, not something that only applies downstream.

Mistake 2: Shipping without a current Safety Data Sheet

A missing or outdated Safety Data Sheet (SDS) is one of the fastest ways to create liability. SDS documents must follow the GHS / HazCom 2012 format, and an old or incorrect version can misstate exposure limits or handling instructions. Confirm your supplier provides an SDS that matches the current formulation of the product, not a generic or outdated template.

Mistake 3: Treating container labels as optional

Labelling under OSHA HazCom is a separate requirement from the SDS, and it's easy to assume one covers the other. If a container arrives without proper hazard labelling, the buyer has no way to identify risks at the point of use. Check that labels travel with the product, not just in a separate document packet.

Mistake 4: Not knowing the actual exposure limits

OSHA sets specific permissible exposure limits (PELs) for substances such as benzene (1 ppm, 8hr TWA), formaldehyde (0.75 ppm, 8hr TWA), respirable silica dust (0.05 mg/m³), and asbestos (0.1 fibers/cc). Importers who don't know these numbers can't verify whether a supplier's claims are realistic. Ask suppliers for exposure monitoring records rather than taking verbal assurances at face value.

Mistake 5: Having no record of training or emergency planning

Even with correct documents on hand, a buyer may ask for evidence that workers were trained on hazards and that an emergency response plan exists for the product in use. Employee training records and an emergency response plan are part of what OSHA 29 CFR 1910 compliance expects further down the chain. Keep these on file and ready to share when a buyer or distributor requests them.

Mistake 6: Managing documents separately from supplier relationships

Compliance paperwork tends to go stale when it's stored separately from the supplier relationship it belongs to. Build a habit of refreshing SDS, labels, and training records whenever a formulation or supplier changes, as part of your [supplier compliance](/supplier-compliance) process.

If you want a simpler way to keep these documents organized and current, Complyra is worth a look.