Does a non-hazardous product need an SDS?

No. Under OSHA's Hazard Communication Standard, a safety data sheet is required only for a "hazardous chemical": one classified as posing a physical hazard, a health hazard, a simple asphyxiant, combustible dust, or a hazard not otherwise classified. Chemical manufacturers and importers "shall obtain or develop a safety data sheet for each hazardous chemical they produce or import", and employers "shall have a safety data sheet in the workplace for each hazardous chemical which they use." A product that a chemical manufacturer or importer evaluates and does not classify into any of those hazard classes is not a "hazardous chemical" under the standard, and section 1910.1200 does not require an SDS for it. (29 CFR 1910.1200(c) "Hazardous chemical"; 1910.1200(g)(1))

This guide covers the US OSHA standard; Canada (WHMIS) and the EU (REACH) have their own rules.

What counts as a "hazardous chemical"

The SDS duty in (g)(1) is written around one defined term, and a product only needs an SDS if it falls into one of the term's five hazard classes:

• Physical hazard: a chemical classified as explosive, flammable, an aerosol, a chemical under pressure, an oxidizer, self-reactive, pyrophoric, self-heating, an organic peroxide, corrosive to metal, a gas under pressure, one that emits flammable gas in contact with water, or a desensitized explosive. (29 CFR 1910.1200(c) "Physical hazard")
• Health hazard: a chemical classified as posing acute toxicity, skin corrosion or irritation, serious eye damage or eye irritation, respiratory or skin sensitization, germ cell mutagenicity, carcinogenicity, reproductive toxicity, specific target organ toxicity, or an aspiration hazard. (29 CFR 1910.1200(c) "Health hazard")
• Simple asphyxiant: a substance or mixture that displaces oxygen in the ambient atmosphere. (29 CFR 1910.1200(c) "Simple asphyxiant")
• Combustible dust: finely divided solid particulates that pose a flash-fire or explosion hazard when dispersed in air or other oxidizing media. (29 CFR 1910.1200(c) "Combustible dust")
• Hazard not otherwise classified (HNOC): an adverse physical or health effect found during classification that does not meet the specified criteria for the hazard classes in the standard. This does not cover an effect that falls below a hazard class's own cut-off value, or that sits under a GHS category OSHA has not adopted. (29 CFR 1910.1200(c) "Hazard not otherwise classified (HNOC)")

A product that a proper classification places outside all five is, by the standard's own definition, not a hazardous chemical, and the SDS duty in (g)(1) does not reach it.

Who decides, and against what criteria

Classification is the chemical manufacturer's or importer's job, not the employer's. They evaluate each chemical they produce or import and determine which hazard classes, and categories within a class, apply to it, including any hazard that arises from a change in physical form or from a reaction product of known or reasonably anticipated use. Employers are not required to classify a chemical themselves unless they choose not to rely on the classification they received. (29 CFR 1910.1200(d)(1))

Classification considers "the full range of available scientific literature and other evidence concerning the potential hazards", with no requirement to test the chemical. Appendix A to 1910.1200 sets the health-hazard criteria; Appendix B sets the physical-hazard criteria. (29 CFR 1910.1200(d)(2))

A hazardous product can still be exempt, on different grounds

A "non-hazardous" product and an exempt product are not the same question, and the standard keeps them on separate paragraphs.

The (b)(6)(ix) row matters for a genuinely hazardous product sold for consumer use: where the employer can make the showing it requires, the product is fully outside 1910.1200, including the SDS duty, without ever being reclassified as non-hazardous. The (b)(5) row is the opposite trap: a labeling exclusion under (b)(5) is often mistaken for a full exemption, but the paragraph's own text confines it to labeling.

Using the SDS Section Guide once one applies

None of this changes what an SDS must contain once the duty in (g)(1) does apply. The SDS Section Guide walks through the 16 sections OSHA requires in that case, in the order (g)(2) lists them, from Section 1 Identification through Section 16.