What this is
What is a safety data sheet review?
What is a safety data sheet review?
A periodic check, run per product, that the safety data sheet held for a substance is the current version, contains all sixteen sections in usable form, and is available to the people who use the product. It reviews the record, not the chemical: the sheet itself is the supplier's document, and the review is the employer's evidence that the duty to maintain and provide it has actually been discharged.
How often should safety data sheets be reviewed?
Yearly per product is the working norm this template applies, with a review forced earlier by any trigger: a reformulation, a supplier change, a new or revised exposure limit, or a regulatory reclassification. Manufacturers must revise a sheet within three months of learning significant new hazard information under OSHA 1910.1200(g)(5), and within 90 days under WHMIS 2015, but nobody delivers the revision to past purchasers. The employer only benefits from the supplier's duty by checking.
Do safety data sheets expire?
Not by a fixed clock in the United States: HazCom sets no expiry date. Under WHMIS 1988 a data sheet expired at three years; WHMIS 2015 removed the fixed expiry in favour of the supplier's 90-day update duty, and Australia requires manufacturers to review sheets at least every five years. A three-year flag, which this template applies, is the conservative practical standard: a sheet that old has outlived at least one plausible reformulation and deserves a supplier confirmation.
Scope
When is a safety data sheet review required?
The review sits between the sheet itself and everything built on it. Its most common misuse is being stretched to do the neighbouring jobs: authoring sheets, assessing tasks, or fixing labels, each of which has its own template and its own record.
Use this template when
- The yearly review cycle for a substance falls due, one record per product
- A new or revised sheet arrives from the supplier and must be verified before it replaces the old one
- A regulatory change lands: a reclassification, a new exposure limit, or a jurisdiction adopting a newer GHS revision
- A spill, exposure or first-aid event showed the sheet being used in anger, well or badly
- The chemical risk assessment for the substance is due for renewal and needs a verified sheet as its input
Do not use it for
- Holding or authoring the sheet itself, which is the Safety Data Sheet record and, for purchased products, the supplier's legal duty
- Assessing the risk of using the chemical for a task, which is the Chemical Risk Assessment covering exposure route, quantity, ventilation and controls
- Recording what is held where and in what quantity, which is the Chemical Inventory Record against the substance register
- Checking container labelling, which is the Workplace Label Record; the label and the sheet are separate duties
- Spot-checking access on the floor between review cycles, which is the lighter Data Sheet Availability Check
Compliance mapping
Which OSHA 1910.1200(g) requirements does this satisfy?
Hazard communication regimes split the duty: the supplier must produce and update the sheet, the employer must obtain it, keep it, and make it reachable. The review exists because the second duty is continuous and the first one is invisible from your side of the transaction.
| Clause | Requirement | Where it lands |
|---|---|---|
| OSHA 1910.1200(g)(1) | Employers must have a safety data sheet for each hazardous chemical they use, obtained from the supplier or developed | Header |
| OSHA 1910.1200(g)(2) | Sheets must follow the sixteen-section format with the headings and order prescribed in Appendix D | Completeness |
| OSHA 1910.1200(g)(5) | Manufacturers and importers must revise the sheet within three months of becoming aware of significant new hazard information | Currency |
| WHMIS 2015, Hazardous Products Regulations (SOR/2015-17) | Supplier sheets must be compliant at the time of sale, in English and French, and updated within 90 days of significant new data | Currency |
| OSHA 1910.1200(g)(8) | Copies must be readily accessible during each work shift to employees when they are in their work areas | Availability |
| OSHA 1910.1200(h) | Workers must be trained on the hazards and on how to obtain and use the data sheet and other hazard information | Downstream |
| HSE COSHH reg.6 | The exposure assessment must be reviewed when there is reason to suspect it is no longer valid, including new hazard information | Downstream |
| EU REACH Art.31 and Annex II | Sheet format and content prescribed; suppliers must update without delay when new hazard or restriction information emerges | Completeness |
What it does not cover
- The safety data sheet itself, which is authored by the manufacturer or importer and held as its own record; the review verifies the sheet, it does not create one.
- Chemical risk assessment, which assesses the substance as used in a specific task, covering exposure route, quantity, duration and ventilation; the review only flags whether that assessment is still valid.
- The chemical inventory, which records what is held where, in what quantity and in what container, reconciled against the substance register.
- Workplace labelling, which is a separate duty with its own record; a current sheet does not prove the decanted container in the wash bay is labelled.
- Hazard communication training, which the review can flag as needing an update but which is delivered and evidenced through the training record, not here.
Global
Safety Data Sheet Review requirements by country
Every major regime requires sheets to be obtained, kept current and made available. What differs is who carries the update duty, how fast it bites, and whether currency has a fixed clock.
OSHA 29 CFR 1910.1200(g), HazCom aligned to GHS
Employer must have a sheet per hazardous chemical, readily accessible each shift; manufacturer must revise within three months of significant new information.
There is no expiry date, so an inspector tests accessibility and coverage against the inventory rather than sheet age, and a missing sheet is cited per chemical.
WHMIS 2015: Hazardous Products Act and Regulations, plus provincial OHS employer duties
Supplier sheets compliant at sale, bilingual, updated within 90 days of significant new data; employers must make sheets readily available to exposed workers.
The old three-year expiry is gone federally, which moved the burden onto employers to actively confirm currency instead of watching a date.
UK REACH Art.31 and Annex II; COSHH for the downstream duties
Suppliers must provide and update compliant sheets; employers must assess exposure under COSHH using them and review when information changes.
HSE enforcement lands on the COSHH assessment built from the sheet, so a stale sheet becomes an invalid assessment rather than a paperwork finding.
REACH Regulation (EC) 1907/2006 Art.31 and Annex II; CLP for classification
Prescribed sheet format; updates without delay on new hazard information, supplied to all recipients of the previous twelve months.
The twelve-month recipient rule means recent purchasers should receive updates unprompted, and a supplier who does not is itself non-compliant.
Model WHS Regulations and the SDS code of practice
Manufacturers and importers must review and, if necessary, amend sheets at least every five years; employers must obtain current sheets and keep them accessible in a register.
Australia is the regime with a real clock: a sheet issued more than five years ago is non-compliant on its face, which makes the age check a hard test rather than a heuristic.
UN GHS (the Purple Book)
The sixteen-section sheet format and hazard classification system that national regimes implement, at differing revision numbers.
Jurisdictions adopt different GHS revisions on different timetables, so a multinational supplier's newest sheet may still be behind the revision your regulator has adopted.
How to complete it
How to complete a safety data sheet review, step by step
The form will happily record a pass for a sheet that is present, sixteen sections long and useless. The record is only worth keeping if four judgement calls are made honestly.
The SDS Issue Date and Age In Years fields tell you how old your copy is; they cannot tell you whether it is current. For any sheet near or past the three-year flag, the conditional fields exist to be used: contact the supplier, record it, and record whether an updated version actually arrived. A review that flags age without chasing it has documented a known deficiency and left it standing.
Composition, exposure limits, first aid, fire fighting and spill measures are the sections read under time pressure by someone who is not a chemist. Partial is a legitimate score for a cosmetic gap elsewhere; on these sections it should be treated as a fail with a deadline, because a first-aid section that is technically present but unclear will be discovered to be unclear at the worst possible moment.
The three Availability fields are a single question asked properly: can the person who splashes the product at 03:00 read the sheet within a minute or two? Walk to the point of use, try the access route the workers actually have, and try it with the network down. Asking a worker where they would find the sheet is the only honest way to answer the third field, and their blank look is a finding.
Risk Assessment Still Valid, Training Needs Updating and Action Required are the review's whole point: a revised sheet with a new hazard classification or exposure limit silently invalidates the assessment and the training built on the old one. Closing the review with these answered No by reflex, or with an action raised but no CAPA reference, owner or priority, makes the review decorative.
What auditors find
Most common safety data sheet review findings
Data sheet findings rarely say the sheet is missing. They say the library was maintained as a library, while the products, the suppliers and the regulations moved.
| Finding | Clause | What fixes it |
|---|---|---|
| Sheet on file predates a known reformulation or supplier change for the product being purchased. | OSHA 1910.1200(g)(1) | Match the sheet's product identifier and revision to the current purchase; raise a data sheet request to the supplier and record the chase. |
| Legacy MSDS-format sheets still in the library, missing the sixteen-section structure. | OSHA 1910.1200(g)(2) | Flag any pre-GHS sheet for replacement regardless of age; the format itself is the non-compliance. |
| Sheets older than three years with no supplier contact recorded. | OSHA 1910.1200(g)(5) | Work the Currency conditionals: contact the supplier, log the response, and set an action if no updated version arrives. |
| Electronic-only access behind a login or network dependency, with no fallback for an outage. | OSHA 1910.1200(g)(8) | Provide a barrier-free route: a shared terminal with no login friction plus a printed or offline backup at the point of use. |
| Exposure limits section blank or citing only a foreign jurisdiction's limits. | OSHA 1910.1200(g)(2) | Score Exposure Limits Stated as a fail and obtain a sheet citing the limits applicable where the product is used. |
| Spill measures cite an absorbent or neutraliser the site does not stock. | OSHA 1910.1200(g)(1) | Either stock what the sheet requires or verify the spill kit contents are an accepted equivalent, and record which. |
| Sheet available only in English at a site where part of the workforce cannot read it. | WHMIS 2015 / OSHA 1910.1200(h) | Obtain the supplier's other-language versions where they exist and close the gap through comprehensible training where they do not. |
| Chemical risk assessment not reviewed after a sheet revision changed the hazard classification. | HSE COSHH reg.6 | Answer Risk Assessment Still Valid honestly and link the assessment record so the review raises its update. |
| Products in the inventory with no review record, or reviews for products no longer held. | OSHA 1910.1200(g)(1) | Reconcile the review cycle against the substance register so coverage is per product held, not per sheet filed. |
| Actions raised at review closed without an owner, priority or CAPA reference. | OSHA 1910.1200(e) | Complete the Downstream action fields at closure; an unowned action is a finding deferred to the next audit. |
Case in point
Case in point: the sheet that passed six reviews and failed at three in the morning
A packaging plant used a solvent degreaser on its night maintenance shift. The safety data sheet library was reviewed annually and the degreaser's sheet passed every year: present, sixteen sections, legible. Access was through the intranet document system, which the reviews recorded as available because it opened first time from the reviewing coordinator's desktop.
A fitter splashed the product into his eye at 03:00. The sheet was behind an intranet login the night crew did not have; the one supervisor with credentials was on the far side of the site. First aid proceeded from memory for close to twenty minutes before anyone read Section 4. When the sheet was finally retrieved, it was the 2017 issue for a formulation the supplier had replaced in 2022, and its first-aid wording differed from the current sheet in exactly the line that mattered, the recommended rinse duration.
Neither failure was visible from the coordinator's desk. Availability had been tested from the wrong chair at the wrong hour, and currency had been read off the file instead of the supplier. The corrective action was not a better binder: it was point-of-use access with no login, an offline fallback, and a review step that contacts the supplier for every sheet past three years, which is precisely the pair of checks this template hard-codes.
The template
The template, field by field
The form exactly as it installs. Every field, option, score and conditional rule is editable, and the links to other templates come with it.
6 sections
- Reference
- SAF-085
- Archetype
- Review
- Record ID
- SDSR-2026-000
- Scoring
- Currency percent
- Direction
- High is good
- Singleton
- No
- Basis
- OSHA 1910.1200(g), WHMIS
- Links
- Links Substance
- Tags
- Chemical, Compliance
- Sections
- 6
- Fields
- 38
- Follow up fields
- 6
- Repeating sections
- 0
- Links out
- 6
Header
8 fieldsReview ID*
Auto sequence. Format SDSR-2026-000.
The record's own ID. Other templates point at this value.
Status*
Drives who this goes to next.
- Planned2 pts
- In progress2 pts
- Complete3 pts
- Deferred0 pts
- Open0 pts
- Closed3 pts
- Overdue0 pts
Date and Time*
Completed By*
Site*
Site ID*
Format SITE-000.
Links to FDN-001 Site ID
Substance*
Substance ID*
Format SUB-0000.
Links to FDN-006 Substance ID
Currency
5 fieldsSDS Issue Date*
Age In Years*
Within Three Years*
- Yes3 pts
- No0 pts
Supplier Contacted For Update
Updated Version Received
Completeness
9 fieldsAll 16 Sections Present*
- Pass2 pts
- Partial1 pt
- Fail0 pts
- N/Aexcluded from denominator
Language Suitable For Workforce*
- Pass2 pts
- Partial1 pt
- Fail0 pts
- N/Aexcluded from denominator
Composition Section Complete*
- Pass2 pts
- Partial1 pt
- Fail0 pts
- N/Aexcluded from denominator
Exposure Limits Stated*
- Pass2 pts
- Partial1 pt
- Fail0 pts
- N/Aexcluded from denominator
First Aid Measures Clear*
- Pass2 pts
- Partial1 pt
- Fail0 pts
- N/Aexcluded from denominator
Fire Fighting Measures Clear*
- Pass2 pts
- Partial1 pt
- Fail0 pts
- N/Aexcluded from denominator
Spill Measures Match Our Kit*
A sheet telling you to use an absorbent you do not stock is not usable.
- Pass2 pts
- Partial1 pt
- Fail0 pts
- N/Aexcluded from denominator
PPE Matches What We Issue*
- Pass2 pts
- Partial1 pt
- Fail0 pts
- N/Aexcluded from denominator
Disposal Route Matches Our Contract*
- Pass2 pts
- Partial1 pt
- Fail0 pts
- N/Aexcluded from denominator
Availability
3 fieldsAccessible At Point Of Use*
- Pass2 pts
- Partial1 pt
- Fail0 pts
- N/Aexcluded from denominator
Accessible Without Network*
- Pass2 pts
- Partial1 pt
- Fail0 pts
- N/Aexcluded from denominator
Workers Know Where To Find It*
- Pass2 pts
- Partial1 pt
- Fail0 pts
- N/Aexcluded from denominator
Related records
1 fieldSDS ID
The sheet being reviewed.
Links to SAF-176 SDS ID
Downstream
12 fieldsRisk Assessment Still Valid*
- Yes3 pts
- Needs minor update1 pt
- No0 pts
Risk Assessment
Risk ID
Format RSK-2026-00000.
Links to FDN-012 Risk ID
Training Needs Updating*
- No3 pts
- Yes0 pts
Course ID
Links to FDN-007 Course ID
Action Required*
Raise the action record, then enter its reference here.
- No2 pts
- Yes0 pts
Priority
- High0 pts
- Medium1 pt
- Low3 pts
CAPA ID
Format CAPA-2026-00000.
Links to FDN-014 CAPA ID
Action Owner
Next Review Due*
Reviewed By*
Signature*
SAF-085 · record IDs look like SDSR-2026-000 · Links Substance
Open in KnowellaRun it with agents
From a document you fill in to a programme that runs itself
The review itself is an afternoon's work per cycle. What fails is the machinery around it: the reformulation nobody announced, the chased supplier who never replied, and the risk assessment that quietly went stale when the sheet changed.
Holds the review cycle against the substance register, flags every product whose sheet has crossed the age threshold or has no review this year, and routes each record to the chemical coordinator.
Watches incoming sheets, supplier responses and reclassification triggers, chases the Updated Version Received gap on open reviews, and raises the downstream risk assessment and training updates a revised sheet demands.
Connects a review that flags Training Needs Updating to the hazard communication course and its attendees, so a changed sheet produces a training action rather than an assumption.
Reconciles the sheet's spill and disposal sections against the spill kit inspections and waste contract records, so a mismatch surfaces as a finding instead of a surprise.
This template lives in KnowSafe — safety and compliance. Incidents, hazards, permits, inspections and the critical controls behind them.
Meet KnowSafe→Glossary
Safety Data Sheet Review definitions and key terms
- Safety data sheet
- The supplier-authored sixteen-section document stating a hazardous product's identity, hazards, safe handling, exposure limits and emergency measures.
- GHS
- The UN Globally Harmonized System of classification and labelling, which national regimes such as HazCom and WHMIS implement at differing revision numbers.
- Sixteen-section format
- The prescribed structure and ordering of a data sheet, from identification through to regulatory information, mandatory under HazCom Appendix D, WHMIS and REACH Annex II.
- Significant new information
- Data changing a product's hazard classification or protective measures, which starts the supplier's update clock: three months under OSHA, 90 days under WHMIS.
- Readily accessible
- The OSHA accessibility standard: reachable by workers in their work areas during every shift, with no barriers such as logins, locked rooms or network dependence.
- Exposure limit
- The airborne concentration limit for a substance, stated in Section 8 as a PEL, TLV, WEL or national equivalent, and the input a risk assessment cannot proceed without.
- Workplace label
- The label applied when a product is decanted or transferred on site, summarising the sheet's hazards; a separate duty from holding the sheet itself.
- Currency
- Whether the sheet on file is the supplier's latest issue for the formulation actually being purchased, which can only be established with the supplier, not from the file.
FAQ
Frequently asked questions about safety data sheet review
Do safety data sheets expire after three years?+
No regime currently says exactly that. WHMIS 1988 did, and its removal in WHMIS 2015 is why the three-year flag survives as practice rather than law. The United States has no expiry at all, and Australia runs a five-year manufacturer review clock. Treat three years as the point at which a sheet must be positively confirmed with the supplier rather than the point at which it dies, which is precisely how this template's conditional fields behave.
Can we keep safety data sheets electronically only?+
Yes, and most sites should, provided there are no barriers to immediate access: OSHA has been consistent that a system needing a login the crew does not have, a network that goes down, or a terminal far from the work area defeats the accessibility requirement. Keep an offline or printed fallback at the point of use for the products that can hurt someone quickly, and test the access route from the floor, not the office.
Who is responsible for keeping sheets current, us or the supplier?+
Both, in sequence. The supplier must revise the sheet when significant new information emerges, but no regime obliges them to push revisions to everyone who ever bought the product; the EU's twelve-month recipient rule is the closest thing and it is narrow. The employer's duty to have a current sheet is therefore discharged by asking, which is what the Supplier Contacted For Update field records.
Do we need sheets for consumer products like dish soap?+
Not where the product is used the way a consumer would, in consumer quantities and frequencies; HazCom exempts that use. The exemption evaporates when a cleaner is used all shift, decanted, or used in industrial quantity, and the honest test is exposure, not the label. When in doubt, hold the sheet: the cost of an unnecessary sheet is filing, the cost of a missing one is a citation per chemical.
What if the supplier will not provide an updated sheet?+
Document the requests, escalate to the regulator if the product is still on the market, and treat a persistently unresponsive supplier as a procurement problem: the substitution assessment exists for exactly this. Continuing to use a product whose hazards you cannot verify is a risk decision someone senior should make explicitly, not a default.
Does the sheet have to be in the language of the workforce?+
In the United States the sheet must be in English and may additionally be in other languages; in Canada it must be in English and French. Neither answer settles the real question, which is whether the people using the product can act on it. The Language Suitable For Workforce field takes the position that a sheet the crew cannot read fails the review regardless of its legal language, and the gap is closed through translated versions or training, evidenced elsewhere.
Keep going
Related templates and programmes
Industries this is written for
Programmes this belongs to
Used together in Chemical Safety and WHMIS
Spill Report
Records a release of chemical, fuel, oil or wastewater
Spill Response Record
Records what was done to contain, clean up and dispose of a spill
Chemical Substitution Assessment
Assesses whether a hazardous substance can be replaced by something safer, and what the substitute brings with it
Restricted Substance Compliance Record
Records compliance with restricted substance obligations covering ozone depleting gases, persistent chemicals and packaging materials
Explosive Atmosphere Zoning Record
Records the zoning of areas where flammable dust or vapour can form an explosive atmosphere, and the equipment permitted there
Chemical and Substance Register
Lists every chemical and hazardous substance held on site, with quantity, location and hazard class
More in Chemicals
Chemical Inventory Record
Records what chemicals are held where, in what quantity and in what container
Chemical Risk Assessment
Assesses the risk of using a chemical for a specific task, covering exposure route, quantity, ventilation and PPE
Chemical Storage Compatibility Check
Checks that stored chemicals are separated correctly so incompatible products cannot mix
Spill Kit Inspection
Checks spill kits are stocked, sealed, accessible and suited to the chemicals nearby
Chemical Decanting Checklist
Steps through transferring a chemical from one container to another safely, including labelling the new container
Dust Hazard Assessment
Assesses combustible dust risk from materials, housekeeping and equipment
Written and reviewed by
Siddarth Singh
Founder & Chief Executive Officer, Knowella
Certified Safety Professional and industrial and systems engineer with more than a decade inside food supply chain, freight and manufacturing operations. This page was written against the current text of the standards it cites, not against secondary summaries of them.
- Certified Safety Professional (CSP), Board of Certified Safety Professionals
- MBA, University of Chicago Booth School of Business
- MS and BS, The Ohio State University, Industrial and Systems Engineering
- Six Sigma Black Belt
Sources and last review. Reviewed 16 August 2026 against:
- OSHA 29 CFR 1910.1200(g) and Appendix D, Hazard Communication
- Hazardous Products Act and Hazardous Products Regulations SOR/2015-17 (WHMIS 2015, Canada)
- UN Globally Harmonized System of Classification and Labelling of Chemicals (GHS)
- REACH Regulation (EC) No 1907/2006, Article 31 and Annex II (EU and UK REACH)
- Control of Substances Hazardous to Health Regulations 2002, regulation 6 (GB)
- Safe Work Australia model WHS Regulations and Preparation of Safety Data Sheets code of practice
This page is general guidance, not legal advice. Confirm requirements with your jurisdiction’s regulator.