The SDS FAQ: Content

What items or formats are required on an SDS?

It depends where you live. Each country has their own rules and regulations. For non-U.S. countries see the International section of this FAQ as well as our SDS Hyperglossary entry on the Globally Harmonized System of Classification and Labeling of Chemicals (GHS), a format which is being adopted by many industrialized countries.

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The US adopted the GHS format for SDS's with its most recent revision of the OSHA Hazard Communication Standard (HCS 2012). Appendix D of the standard lists the minimum required elements as well as the required formatting described in paragraph (g) of the Standard.

Prior to HCS 2012, OSHA had no format requirement of any sort. It only required that (a lesser amount of) certain information appear on the MSDSs (SDS did not become the preferred term until OSHA adopted the GHS in 2012). In 1985, OSHA issued a suggested format called OSHA Form 174 (OMB #1218-0072) which defined eight main headers and was a useful template for MSDS authors. As companies began complying with the original 1984 Standard, some began adding additional information to their MSDS's such as toxicological and regulatory information (information that was becoming required in other countries), and MSDS's began to vary widely in their content and format. Strictly speaking, there was nothing keeping a company from issuing an MSDS as a haiku if they wanted to.

OSHA was unable to enforce a required format without enacting changes to federal regulation, and formatting was, alas, omitted from the 1994 version of the HazCom Standard. In 1993, the American National Standards Institute's (ANSI) published "Hazardous Industrial Chemicals - Material Safety Data Sheets - Preparation, ANSI Z400.1-1993" which promulgated a 16-part standard format and content, and this format quickly gained widespread international use and acceptance - so much so that OSHA quickly started recommending the ANSI format over Form 174. The ANSI standard was obviously incorporated into the GHS which was being developed around that time.

Full implementation of HCS 2012 took effect June 1, 2016 in the US, and GHS-formatted SDS's are now required with new shipments of chemicals. Still, your current collection may contain older MSDS's that do not meet the current format. Not to worry - there is no need to go through your collection and find SDS's for materials received prior to June 1, 2015 - but as you receive new shipments of those older materials, you will need to update your SDS collection with the new sheets just as you always have.

Is there a unique identification code for each chemical?

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Yes, Chemical Abstracts Service (CAS) Numbers are the most definitive identifiers, as each is unique and there are now over 114 million entries in the registry. Prior to adoption of HCS 2012 neither CAS numbers nor other unique identifiers were required content on SDS's. Per paragraph (g)(2)(iii) of HCS 2012 and as explicitly stated in Appendix D, section 3(c), SDS's must now contain CAS numbers and other unique identifiers.

The U.S. Department of Defense uses National Supply Numbers (NSN's) (and closely related NIIN numbers) to uniquely and permanently identify items that it purchases. NSN's are not very widespread on SDS's, but are seen once in a while.

EC Numbers (formerly known as EINECS or ELINCS numbers) are assigned to chemicals sold commercially in Europe, but this numbering system covers only ~100,000 chemicals.

UN/NA numbers are another identifying system used in transportation. However, there are only a few thousand UN/NA numbers assigned (out of 114 million+ known chemicals). UN/NA numbers are generally useful only for emergency personnel responding to transportation accidents involving the most commonly used chemicals in commerce. The only place one generally encounters these are on numbered DOT placards.

Does OSHA determine what information is required under health hazard information or can we use our own data?

OSHA has some very explicit requirements listed under Appendices A and B of the HCS 2012 standard. Note, however, per Section A.0.2, this does not require that one perform any testing of chemicals. You may simply rely on the available scientifically valid data (if any).

Under Appendix B of the now-obsolete HCS 1994 standard and earlier versions, there was only a terse set of general guidelines. Chemical manufacturers, importers, and employers evaluating chemicals were not required to follow any specific methods for determining hazards as long as they could show that they "adequately ascertained" the hazards of the chemicals. Given the relatively low requirements, it has been said that this portion of the HCS 1994 "put the fox in charge of the henhouse."

This change in required hazard information reflects the shift from the HCS's original "hazard determination" requirement to one of "hazard classification". The difference in these terms is very significant. See our SDS HyperGlossary entry on Hazard Classification for more information.

Do I need to make a new SDS if I mix several other chemicals together (each of which already has an SDS)?

Paragraph (d)(3) and Appendices A and B of the OSHA HazCom Standard address this question in considerable detail. There are several different cases to consider:

Per paragraph (d)(3)(i), if you have a non-interacting mixture of components then you can simply make a new SDS based on the sheets you already have. This principle has been part of the HCS since its inception; for example, see this OSHA Interpretation titled "MSDS requirements for products that are composed of a mixture of non-interacting chemicals".

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If you have a complex mixture such as crude oil where the exact chemical composition may vary from batch to batch you can get away with one generic SDS to cover a range of compositions per 29 CFR 1910.1200 paragraph (g)(4). In fact, petroleum mixtures are so complex, they merited their own separate appendix to CPL 02-02-079, the OSHA document which defines the inspection procedures for the HazCom Standard. These older OSHA interpretation letters may also still be relevant:
- "Generic MSDSs to cover different products that contain the same chemicals in different proportions"
- "One MSDS may apply to multiple complex mixtures having similar hazards."
In most cases, the components will interact or chemically react to create another product. If so, a new SDS must be constructed which means you will need to go through the rigorous process of hazard classification which is described in Appendix A of HCS 2012.

The word "mixture" appears 331 times in Appendix A. Recall that no testing is required, but if no test data is available, then one must rely on a series of "bridging principles" for each hazard class. If those are not available, then a series of cut-off values and concentration limits are applied. And each type of hazard class has its own set of rules. Unless you're a toxicologist, your head will probably explode trying to understand it all. For example, try reading just section A.0.5 of Appendix A which discusses bridging principles in general. Therefore, in these cases, you would most likely require professional assistance. Also see Who can write an SDS? (below) for some further insights and guidance.
If the workplace where the mixture is created qualifies as a laboratory under the OSHA Laboratory Standard and the mixture is used solely within the laboratory itself, then no SDS is required per 29 CFR 1910.1450(h)(1)(i). But if that material is shipped to other locations (even other laboratories), one is required as discussed in the next question.

The mind-blowing requirements for mixtures under HCS 2012 may seem like regulatory overkill, but they really are not. When you mix substances that undergo chemical reactions, the resulting mixture may have completely different properties, risks, and hazards. For example, mixing aqueous ammonia and iodine together produces nitrogen triiodide, a powerful contact explosive, a hazard that would not be indicated by the SDS of either starting material.

Do I have to write an SDS for new chemicals that I create in the laboratory?

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Generally, no. But if you plan on distributing these chemicals to others outside of your laboratory (for example, sending samples to other researchers), then you meet OSHA's definition of a chemical manufacturer and must create an SDS for the materials. This is assuming the new chemical meets OSHA's definition of hazardous, which is a fairly good assumption for most chemicals. While this sounds daunting - creating an SDS for a few grams of material that nobody has ever made before and has myriad unknown properties, most of the information on your SDS will simply read "Not known" or something similar. See the question Who can write an SDS? for authoring tips.

This applies for any amount of material you may be wishing to send elsewhere. The HazCom Standard is based on whether on not a material is hazardous, not the risk associated with a given amount of hazardous material.

For an official OSHA interpretation on this see "Material safety data sheet requirements for experimental chemical mixtures that are shipped off-site" dated February 5, 2004.

As a distributor, can we change the name and address on an SDS?

This is a common question from distributors and resellers who do not wish to reveal the identity of their original supplier out of fear that their customers will then purchase the product directly from the manufacturer.

Per Paragraph G.3.b of OSHA Directive Number CPL 02-02-079 there is no problem with a distributor adding their name to an SDS:

Distributors that only add their name to an SDS, without removing the manufacturer's or importer's name and contact number, and makes no other changes to the information on the SDS, is not responsible for any information on the SDS.

However, substitution of the distributor's name and contact information for the manufacturer's or altering any of the other content of the sheet makes the distributor the "responsible party", which incurs legal obligations per Paragraph G.3.c. OSHA expects the "responsible party" to be able to provide information beyond that already contained in the sheet:

Distributors who substitute their names on the SDS in place of the manufacturer's or importer's information become responsible for the accuracy and completeness of the SDS...Responsible party means someone who can provide additional information on the hazardous chemical and appropriate emergency procedures, if necessary.

If you issue an altered sheet and can't provide this information or the sheet is inaccurate, you may potentially face OSHA, civil and/or criminal penalties! We know of at least one case where altering a sheet landed a company in a lawsuit and strongly suggest that one seek legal counsel before issuing an altered sheet.

While we're not attorneys, it is clear that you need to do at least the following before issuing a sheet on which you have substituted your own name/contact information. First, ensure that the sheet is complete and accurate and document your efforts to do so. Do not simply assume that the information on a sheet that you decided to alter is correct. Second, ensure that you can provide the emergency contact assistance required; see this OSHA interpretation for a discussion of whether the contact telephone number needs to be available 24 hours per day.

Finally, note that relabeling a container without making a corresponding change to the SDS (or vice-versa) is prohibited per Paragraph G.3.d:

The company name on the label and on the SDS must be the same. If the distributor removes the manufacturer's name from the label but leaves it on the SDS, they are not in compliance with the standard.

Who can write an SDS?

In theory, anyone can write an SDS as long as they are capable of filling out the OSHA-required elements outlined in Appendix D of the Hazard Communication Standard. Whether you have the expertise it takes to produce an accurate and complete sheet is another matter.

Note: Paragraph A.4.2.2 of Annex 4 of the model regulations for the Globally Harmonized System of Classification and Labelling of Chemicals (GHS), on which the OSHA HazCom Standard is based, states The safety data sheet shall be prepared by a competent person who shall take into account the specific needs of the user audience, as far as it is known. Persons placing substances and mixtures on the market shall ensure that refresher courses and training on the preparation of SDS be regularly attended by the competent persons. However, the term "competent person" is not actually defined, and OSHA did not incorporate this requirement into the language of HCS 2012. The European Union addressed this issue in EU regulation 453/2010 which amended the REACH regulation to cover this in paragraph 0.2.3 which states Suppliers of substances and mixtures shall ensure that such competent persons have received appropriate training, including refresher training.

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Prior to implementation of the 2012 version of the HCS, one only needed to perform a hazard determination, a task that was much easier than the hazard classification that is now required. HCS 2012 also introduced some important new elements such as signal words (either Danger or Warning), pictograms, precautionary statements and hazard statements that had not previously been required.

While these new elements are not all that difficult to figure out, the hazard classification process can be quite daunting to many. Unless your SDS is for something common for which you can use other SDS's as a starting point, or for a laboratory sample for which most of the information may be "not applicable (N/A)" or "none", then you may want to consider hiring a professional. But if you want to try, OSHA has a guide titled Hazard Classification Guidance for Manufacturers, Importers, and Employers that will greatly assist you in the hazard classification process. They also have numerous technical information resources available that can assist SDS authors.

Regardless, recognize that you assume some significant legal responsibilities (see earlier in this section) as the author of an SDS. So if you do not think you are capable of producing an SDS that can meet all the requirements, we suggest outsourcing the project.

Although this article was authored well before HCS 2012 was written, you can find some excellent tips on writing an effective (M)SDS at http://www.osha.gov/dsg/hazcom/hc2inf2.html. This 1997 study includes a finding that "one expert panel review established that only 11% of the MSDSs were found to be accurate in all of the following four areas: health effects, first aid, personal protective equipment, and exposure limits. Further, the health effects data on the MSDSs frequently are incomplete and the chronic data are often incorrect or less complete than the acute data". Therefore, while you can easily make a new SDS for a common chemical (such as acetone) using another sheet as a template, be sure to triple check the information and document your effort!

One easy way to look up or double check technical information required on SDS's is OSHA's Occupational Chemical Database. Here you'll find concise data on a large number of chemical substances that may be encountered in industrial hygiene investigations. It's not all the data you'll need, but it gives you a good start. The RTECS database is another good resource and contains toxicology information on over 168,000 compounds! Those writing sheets for the European market should check out the link to the European Chemical Bureau in our FAQ question on European SDS requirements.

One truly fantastic resource now coming up to speed is the NIH's PubChem open chemistry database which has Laboratory Chemical Safety Summaries (LCSS) on over 152,000 compounds as of February 2022. The key point of this resource is that every piece of data is referenced back to the original source materials, meaning that you are not relying on secondhand information and can document where you came up with the physical or toxicological data on the sheet that you are authoring. Moreover, the LCSS also includes multiple sources for most data, so the user can look at the variability and reliability of the data when deciding which value to enter on their SDS. We expect LCSS's to revolutionize the way that chemical safety data is communicated and, in particular, to greatly assist the hazard classification process.

If you are interested in taking a professional SDS authoring course, AIHA offers an SDS and Label Authoring Registry self-study course ($499 for members, $699 for non-members) as well as a Safety Data Sheet Registered Professional (SDSRP™) credential.

Where does one submit SDS's for official approval?

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Nowhere. OSHA neither accepts SDS's for review nor maintains a national database of SDS's. In general, OSHA reviews SDS content only during an investigation or inspection. This makes sense, as there are millions of SDS's in circulation and OSHA has much better ways to use their rather limited resources.

The manufacturer, distributer, importer or other "responsible party" listed on the sheet is responsible for the accuracy and completeness of the information on the SDS. See "Does OSHA determine what information is required under health hazard information or can we use our own data?" and "Are we protected from liability if someone is injured because an SDS supplied to us is wrong but we had no way of knowing about the error?" elsewhere in this FAQ for more information.

OSHA has a guide titled Hazard Classification Guidance for Manufacturers, Importers, and Employers that is a must-read if you are the author of a SDS. They also have numerous technical information resources available that can assist SDS authors. Or you can always hire an experienced professional to write your SDS's for you.

There at least one for-profit company that bills its "National SDS Repository", however this is simply a (well-done) exhaustive list of links to manufacturer's web sites, not an actual repository, and it is not affiliated with or required by any government agency.

How do I know if an SDS is accurate?

There is no guarantee an SDS is accurate. As discussed in the previous two FAQ questions on this page, anyone can write an SDS and there is no agency that reviews or approves them.

While the United States legal requirements for the content of an SDS as well as the procedures for performing the hazard classification for a chemical are provided in the Appendices of 29 CFR 1910.1200, the OSHA Hazard Communication Standard, the end user of the SDS generally has to take it on faith that the author(s) of the sheet followed the procedure correctly and did full due diligence in doing so. This is not always the case, and inaccuracies on SDS's are fairly common.

For general laboratory and commodity industrial chemicals, many in the chemical safety community have found that SDS's authored by major US manufacturers and laboratory supply companies such as Millipore Sigma (Aldrich), Thermo Fisher Scientific, and VWR/Advantor tend to be above average in reliability. Likewise, for consumer products, major national brand names also tend to be more reliable. Generally, major companies with diverse product lines are more likely to have rigorous systems in place for authoring SDS's, but this is just a rule of thumb. However, there is no guarantee that just because a company is big or well-known that the SDS is accurate, and smaller companies are certainly capable of producing an accurate sheet if they devote the necessary resources.

Folks who have concerns about a sheet's accuracy often compare the SDS's for the same material from different manufacturers. If one finds inconsistencies between different sheets for the same chemical, particularly regarding measures of toxicity, flammability, personal protective equipment, or other areas of concern, it is a good idea to look up original sources of scientific data for those items. While few sheets list their source data, several excellent data resources are discussed in the FAQ question "Who can write an SDS? above.

A 2022 article titled When Safety Data Sheets are a Safety Hazard which appeared in Org. Process Res. Dev. 2022 provides examples of erroneous statements found in SDS's and analyzes their origins, however this article is paywalled.

While we are not attorneys and this is not legal advice, if you have doubts about the accuracy of an SDS you were provided with, it is probably a good idea to document your research as well as what actions you did or did not take based on your findings.

In the European Union, the responsibility for the accuracy of an SDS falls not just on the original author, but on others in the downstream flow. Specifically:

In all cases, suppliers of a substance or a mixture which requires a safety data sheet have the responsibility for its contents, even though they may not have prepared the safety data sheet themselves. In such cases, the information provided by their suppliers is clearly a useful and relevant source of information for them to use when compiling their own safety data sheets. However, they will remain responsible for the accuracy of the information on the safety data sheets they provide (this also applies to SDSs distributed in languages other than the original language of compilation). It should be noted that the supplier always needs to add their contact details in Section 1.3 of the SDS, even when they use the SDS from their supplier without changing any content (see section 3.1 of this guidance document for more details).

See the ECHA document Guidance on the compilation of safety data sheets.

Are SDS's copyrighted/copyrightable?

Disclaimer: we are not intellectual property attorneys etc., so this is our non-expert response to this question.

Manufacturers, distributors etc. are required to give SDS's to downstream users at no charge so there is really no point in formally copyrighting them. In fact, given that HCS 2012 requires SDS's to follow a standard format and language, it is unlikely in most cases that one would be able to have an enforceable copyright. One could reasonably argue that most SDS's are derivative of previous ones or that they simply constitute a list of facts, neither of which merits an enforceable copyright.

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On the other hand, if one "gussies up" a sheet with a particular graphic design, organization, and other elements that represent original creative work, then the sheet (in that form) could theoretically be copyrighted. Of course, nothing prevents someone from extracting the basic scientific facts and printing them in a different form.

Over the years we have seen at least a few companies produce SDS's with copyright notices. Whether that is an enforceable copyright is unclear. We are unaware of any successful litigation involving violation of an SDS copyright. That said, we are aware of a several instances in which someone had posted SDS's to a web site and was sent a takedown notice under the Digital Millennium Copyright Act. Those are tough to beat. If the author of the sheet issues one of those and you want to contest it, you will probably need a lawyer or may have to relocate your web/business presence to a country outside US legal jurisdiction.

See SIRI's site for another opinion. There are lots of other great web sites on copyright law; a quick search at Yahoo, Google, Teoma etc. should offer hundreds of possibilities.

The complexity of this goes way beyond the copyright aspect. Imagine a manufacturer being sued by a client who needed an SDS that was required by law....but who couldn't get it because of a confusing copyright issue...and then there being an accident involving that material...and someone suffering great pain, injury or death. Could be quite ugly. On the other hand, consider the viewpoint of a manufacturer who issues regular updates to their SDS's and does not want multiple outdated versions of them floating around in cyberspace; what happens if there is an emergency and someone grabs an old version with incorrect or outdated information?

Either way, these scenarios illustrate that free and unfettered access to safety information is the best way to go. All manufacturers should post their SDS's on their web site and ensure that every sheet includes a permanent web link (no more broken URL's!) where the user can go to see if they have the latest version.

Is there an XML standard for SDS's?

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The Defense Environmental Network & Information eXchange (DENIX) has been working on draft DTD's (data type definitions) for MSDS's and they welcome your insight and input on the proposed standard. However, we have not noted any changes in this site (and therefore progress on the DTD) since 2010, and the current information available is quite sparse, as you can see.

More recently, eSDSCom has been working on an industry consensus format they call SDScomXML. They have released an operational version that you can download, but we haven't taken a look at it ourselves. They are apparently planning to publish an updated version in spring of 2017. If anyone has further information or experience with this effort, we'd love to hear from you.

XML stands for eXtensible Markup Language, an configurable extension of HTML, the language used to author web pages. XML permits industries to come up with a set of tags that define information content within a document, not just document structure. For example, in an SDS, one could surround the address information with <address>...</address> tags or the CAS number with <cas>...</cas> tags. These tags would be invisible to the reader, but any computer reading the document could automatically extract (or insert) this information. That allows the data to be imported/exported to databases, cell phones, internet appliances etc. with no human intervention, and provides superior data access. We strongly support and encourage the development of an SDS XML standard.

For more about XML, see World Wide Web Consortium (WC3)'s XML recommendations.

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The Safety Data Sheet (SDS) FAQ: Content

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