01
Why every SDS looks the same
The chemical manufacturer or importer must write the SDS in English and use at least the 16 numbered headings, in order (§1910.1200(g)(2)). Appendix D's Table D.1 lists the minimum information under each heading. Inside a section the preparer may present that information in any order. What a section can't be is blank: if no relevant information is found for a subheading, the sheet has to say so (§1910.1200(g)(3)).
The fixed layout arrived when OSHA aligned HazCom with the GHS in 2012. The older material safety data sheet (MSDS) had required content but no required order, which is why an MSDS-era sheet for a product you still use is a reason to ask the supplier for the current SDS. Your copies can be in other languages too, as long as the English version exists (§1910.1200(g)(2)).
02
Sections 1–3: what the product is and what is in it
| Section | What it must contain, and what to check |
|---|---|
| 1 · Identification | The product identifier used on the label, other means of identification, recommended use and restrictions on use, the name, U.S. address, and U.S. phone number of the manufacturer, importer, or other responsible party, and an emergency phone number. Check: the product identifier matches the container label and the name on your chemical list. The standard defines the identifier as the cross-reference between the list, the label, and the SDS (§1910.1200(c)). |
| 2 · Hazard(s) identification | The chemical's hazard classification; the signal word, hazard statements, pictograms, and precautionary statements (pictograms may be shown as black-and-white graphics or by name, such as "flame"); hazards from reaction products of the chemical's known or reasonably anticipated uses (§1910.1200(d)(1)(ii)); hazards not otherwise classified; and, where an ingredient of unknown acute toxicity makes up 1% or more of a mixture not classified by testing it as a whole, a statement of what percentage of the mixture is of unknown acute toxicity, by route of exposure. Check: the signal word and pictograms match the container label. Reaction-product hazards and hazards not otherwise classified can appear here without appearing on the label (§1910.1200(f)(1)), and a shipped drum may omit a pictogram when a DOT transport label covers the same hazard (§1910.1200(f)(5)(iii)). |
| 3 · Composition / ingredients | For a substance: chemical name, common names and synonyms, CAS number or other unique identifiers, and any classified impurities or stabilizers that contribute to its classification. For a mixture: the same for every ingredient classified as a health hazard that is present above its cut-off value, or that presents a health risk below it, with its exact concentration. Ranges are allowed only for a trade-secret claim, batch-to-batch variation, or a group of substantially similar mixtures. Check: a trade-secret claim says so on the sheet, and a withheld concentration is given as a range the standard allows: one of its prescribed ranges (such as 1% to 5% or 30% to 60%), two consecutive prescribed ranges combined (between 0.1% and 30%), or a narrower range (§1910.1200(i)(1)(iv)–(vi)). |
03
Sections 4–8: what to do about it
| Section | What it must contain, and what to check |
|---|---|
| 4 · First-aid measures | Necessary first-aid measures by route of exposure (inhalation, skin and eye contact, ingestion), the most important symptoms, acute and delayed, and whether immediate medical attention or special treatment is needed. Check: the people who respond on your site are trained and equipped for what it says. |
| 5 · Fire-fighting measures | Suitable and unsuitable extinguishing media, specific hazards from the chemical (such as hazardous combustion products), and protective equipment and precautions for firefighters. Check: the extinguishers near where it's stored are a suitable type. |
| 6 · Accidental release measures | Personal precautions, protective equipment, and emergency procedures, plus methods and materials for containment and cleanup. Check: the spill kit in that area has what this section calls for. |
| 7 · Handling and storage | Precautions for safe handling and conditions for safe storage, including incompatibilities. Check: it isn't stored next to anything this section lists as incompatible. |
| 8 · Exposure controls / PPE | For the ingredients in Section 3, the OSHA permissible exposure limit (PEL), the ACGIH Threshold Limit Value (TLV), and any other exposure limit the preparer uses or recommends, where available; appropriate engineering controls; and individual protection measures such as personal protective equipment. Check: the gloves, eye protection, and respirators your people actually use match it. |
04
Sections 9–11: the technical data
Section 9, Physical and chemical properties, lists 18 properties, from physical state, color, and odor through flash point, flammability limits, pH, vapor pressure, solubility, and particle characteristics. Flash point is the one to find first: together with the initial boiling point, it decides whether a liquid is flammable and in which category (Appendix B.6).
Section 10, Stability and reactivity, covers reactivity, chemical stability, the possibility of hazardous reactions (including in foreseeable emergencies), conditions to avoid such as static discharge, shock, or vibration, incompatible materials, and hazardous decomposition products.
Section 11, Toxicological information, describes the likely routes of exposure; symptoms; delayed, immediate, and chronic effects; numerical measures of toxicity such as acute toxicity estimates; interactive effects, where relevant and readily available; whether the chemical is listed in the NTP Report on Carcinogens, has been found to be a potential carcinogen in the IARC Monographs, or by OSHA; and, where specific data wasn't available, what alternative information was used and how. Check: Section 11 states the carcinogen listing status rather than leaving it out.
05
Sections 12–15: required headings, content OSHA doesn't enforce
Four sections sit in a gray zone. To stay consistent with the GHS, an SDS must include the headings for Sections 12 through 15, in order (Note 1 to §1910.1200(g)(2)). But OSHA does not enforce the information under them, "as these areas are not under its jurisdiction" (Note 2), and Appendix D labels them non-mandatory.
They're still worth reading. Section 12, Ecological information, covers ecotoxicity, persistence and degradability, bioaccumulation, and mobility in soil. Section 13, Disposal considerations, describes waste residues and safe disposal, including contaminated packaging. Section 14, Transport information, carries the UN number, proper shipping name, transport hazard class, and packing group, which is where you start if you ship the product. Section 15, Regulatory information, collects other safety, health, and environmental rules that apply to it. Because other agencies' rules govern disposal and shipping, treat these sections as a starting point, not the final word.
06
Section 16: the date that matters
Section 16, Other information, must include the date the SDS was prepared or last changed. It is the quickest way to tell whether you are holding the supplier's current version.
An old date isn't automatically a problem; some products don't change. Two things create an obligation: new information, and rule changes. Whoever prepares the sheet must add significant new information about the chemical's hazards, or ways to protect against them, within three months of learning it (§1910.1200(g)(5)), and the manufacturer or importer must send the updated sheet with the first shipment after the update (§1910.1200(g)(6)(i)). The 2024 HazCom update had to be applied to sheets for substances by May 19, 2026, and must be applied to sheets for mixtures by November 19, 2027 (§1910.1200(j)(2)(i), (j)(3)(i)), so a sheet dated before the update took effect on July 19, 2024 is worth asking the supplier about. When a revised sheet arrives with a delivery, it becomes the working copy that day. Keep the old one rather than throwing it out. Under §1910.1020 you keep either the superseded sheet or some record of the chemical's identity, where it was used, and when, for at least 30 years (§1910.1020(d)(1)(ii)(B)); keeping the sheet is usually easier.
07
A five-minute check before you file a sheet
- All 16 headings, in order, in English — Sections 12 to 15 included as headings, even if thin.
- The Section 1 product identifier matches the container label and your chemical list.
- Section 2 matches the label — the same signal word and pictograms (allowing for a DOT label that stands in for a pictogram).
- Section 3 lists the hazardous ingredients with concentrations — and a trade-secret claim uses a range the standard allows.
- Section 8's protective equipment is what your people actually use.
- No blank subheadings — missing data is marked as not available, not left empty.
- Section 16 has a date — and the supplier's website doesn't show a newer revision.
A sheet that fails goes back to the supplier. The manufacturer or importer must provide an SDS on request (§1910.1200(g)(6)(iv)), and keeping it accurate is the preparer's duty (§1910.1200(g)(5)). Don't correct a supplier's sheet yourself.
When you upload a supplier PDF to SDS HQ, it reads the product name, supplier, hazard codes, ingredients, and revision date off the sheet as it comes in, so most of the filing is done for you: you confirm the fields, and low-confidence reads are flagged for review. The five-minute check is still yours. If you make your own products, SDS authoring writes all 16 sections from your formulation and the physical data you supply, such as flash point, with the classification math shown.
NOTEThis guide is general information about the cited standards, not legal or professional advice for your facility. Regulatory text and agency enforcement practice control; confirm requirements against the standard and your competent person. Claims last reviewed October 13, 2026.