Do Lithium-Ion Batteries Need a Safety Data Sheet?

What does OSHA say?

That the battery is not an article, and that hazard communication applies. In a letter of interpretation dated 23 June 2021, OSHA stated that it "does not consider lithium-ion batteries to be articles under its HCS," because failure during use and handling can present a fire hazard and toxic contaminants can be released.

The consequence is ordinary and unglamorous: safety data sheets, labels, and hazard communication training for the employees who work around them.

So why do manufacturers say the opposite?

We do not know why. We can show you that they do, in their own documents.

  • Flux Power: "The battery is considered an article under OSHA regulations, and an MSDS is not required but provided as a courtesy."
  • EnerSys, safety data sheet 829515H, 20 February 2026: "This standard is not applicable on 'articles' Li-Ion batteries are defined as 'articles' they are exempted from the requirements of the Hazard Communication Standard."
  • Toyota Material Handling: "This battery is an article pursuant to REACH regulation 1907/2006/EC and, as such, do not require the publication of a safety data sheet." That one is a European law reference, not a reading of the American standard.

EnerSys does not agree with itself. Safety data sheet 012608, dated 17 February 2026, three days before 829515H, hedges the identical sentence: Li-Ion batteries "are often considered 'articles', therefore they may be exempted."

The California definition settles it on its own text

This is the part we have not seen anyone else make, and it does not depend on the OSHA letter at all.

8 CCR 5194, Hazard Communication, defines an article as:

"A manufactured item: (1) Which is formed to a specific shape or design during manufacture; (2) which has end use function(s) dependent in whole or in part upon it shape or design during end use; and (3) which does not release, or otherwise result in exposure to, a hazardous chemical under normal conditions of use or in a reasonably foreseeable emergency resulting from workplace operations."

Read clause (3) twice. The test is not only normal use. It expressly includes "a reasonably foreseeable emergency resulting from workplace operations." A lithium-ion battery in thermal runaway releases hazardous chemicals, and every manufacturer document we have read describes that event and tells you what to do about it. A supplier cannot describe the emergency in section 5 of a sheet and simultaneously claim the product cannot produce one.

On the plain text of the California definition, a lithium-ion battery fails clause (3) and is therefore not an article. The OSHA letter of interpretation reaches the same place by a different route.

What does that mean for the employer?

The exposure runs to you, not to the supplier who wrote the sentence.

8 CCR 5194 requires that "The employer shall maintain copies of the required safety data sheets for each hazardous chemical in the workplace, and shall ensure that they are readily accessible during each work shift to employees when they are in their work area(s)." If your hazard communication program leaves the battery out because a vendor said no sheet was required, the person answering that question in an inspection is you.

Three things we do for clients, and you can do them yourself in an afternoon:

  1. Get the sheet anyway. Every manufacturer named above publishes one, including the ones who say it is not required. Ask and it arrives.
  2. File the supplier's statement next to the OSHA interpretation. If the position is ever questioned, the record shows you considered it rather than missed it.
  3. Train on the sheet, not around it. The sections that matter on a job site are fire fighting measures and accidental release, and those are the sections where the manufacturers contradict each other. We compare six of them side by side in our brief on what actually goes on the fire.

Is the sheet actually useful once you have it?

Useful, and not sufficient. The fire fighting section is the reason to have it and also the reason not to rely on it alone.

The Crown and Triathlon safety data sheet for a lithium-ion forklift battery system, revision 4 March 2020, lists as suitable agents graphite powder, copper powder, fire-extinguishing powder, dry sand and ABC powder, and then states: "For safety reasons unsuitable extinguishing agents: Water. Carbon dioxide. Halons." Other manufacturers of the same class of product list water first.

So the sheet tells you what that manufacturer says about that pack, which is exactly what your plan should record and exactly why the plan has to name the pack rather than say "lithium batteries."

How this page was verified

Section 5194 was read on the Department of Industrial Relations site on 11 September 2026 and the definition of article and the safety data sheet access requirement are quoted verbatim from it. The OSHA letter of interpretation was read at osha.gov. The manufacturer quotations were taken from the safety data sheets themselves, with dates as printed inside each document.

The reading of clause (3) is our analysis, and we label it as analysis. It has not been tested by a citation or a decision that we are aware of. If you know of one, tell us and we will publish it.

Every regulation quoted on this page was read in the original on the Department of Industrial Relations site or in the source document, not recalled. Where a question has no settled answer we say so rather than inventing one.

Who wrote this

M Squared Safety Solutions, Inc. is a California occupational safety consultancy and training provider in San Clemente. This page was written by Matthew Horovitz, Competent Person and former OSHA 500 authorized construction outreach trainer, with 20 years in risk management. It is free to read and free to quote with attribution.

What we do about this. We write the plan language for the specific pack on your site, record the determination where the published sources conflict, and train the people who will be standing there. Call 949-954-6581 or book a call.

Related guides

Primary sources

This page describes what the standards say. It is not a safety program, and whether any procedure is right for a particular job site and a particular battery is a determination for that employer, its own competent person, the equipment manufacturer and the authority having jurisdiction.