Summary
In short
- The sixteen sections are fixed in order and content. Sections 12 to 15 are not enforceable under the OSHA standard because they fall under other agencies' authority, but they must still be present.
- OSHA's 2024 final rule aligned the Hazard Communication Standard with GHS Revision 7, changing content in several sections including 2, 3, 9 and 11.
- Compliance dates were extended by four months in January 2026: substances to May 2026 for manufacturers and November 2026 for employers, mixtures to November 2027 and May 2028 respectively.
- Trade secret claims now require disclosure of a concentration range rather than withholding the figure entirely.
- Sections 7 and 8 carry most of the operational content, and section 8 exposure limits are what a chemical risk assessment compares measured exposure against.
- A sheet more than a few years old may predate a reclassification. Currency matters, and suppliers are obliged to provide updated sheets when significant new information becomes available.
What it is
What it is
What is a safety data sheet?
A document supplied with a hazardous chemical, following a globally harmonised sixteen-section format, describing the substance's hazards, composition, handling, exposure controls, physical properties, toxicology and regulatory status.
Is a safety data sheet a risk assessment?
No, and treating it as one is the most consequential error in this area. The sheet describes the substance and gives generic handling advice written without knowledge of your process. A risk assessment describes exposure arising from your use: your quantity, method, duration, frequency and ventilation.
When to use it
When to use it, and when not to
This is a supplier document held and used on site. It informs assessment rather than performing it.
Use it for
- Holding the current supplier sheet for every hazardous chemical on site
- Informing the chemical risk assessment with hazard classification and exposure limits
- Emergency response reference for first aid, fire and spill measures
- Determining storage compatibility and incompatible materials
- Confirming classification changes when a supplier issues a revised sheet
Not for
- The chemical risk assessment, which addresses your use of the substance rather than the substance itself
- Workplace labelling, which follows from the sheet but has its own requirements including secondary containers
- The substance register, which lists what is held on site and where
- Exposure monitoring records, which measure actual exposure against the limits the sheet reports
- Disposal and waste consignment documentation, which follows waste regulation rather than the sheet
Standards
What it is built against
The sixteen-section format is internationally harmonised, with jurisdictional variation in enforceability and detail.
| Clause | Requirement | Where it lands |
|---|---|---|
| 29 CFR 1910.1200(g) | Safety data sheets obtained and maintained for each hazardous chemical, readily accessible to employees | Header |
| 29 CFR 1910.1200 App D | The sixteen-section format and required content for each section | Header |
| HCS 2024 final rule | Alignment with GHS Revision 7, with changes to sections 2, 3, 9 and 11 among others | 2. Hazard identification |
| 29 CFR 1910.1200(i) | Trade secret provisions, now requiring prescribed concentration ranges to be disclosed | 3. Composition and ingredients |
| WHMIS 2015 | Canadian requirements aligned with GHS, with the same sixteen-section structure | 15. Regulatory information |
| EU Reg 1907/2006 Annex II | REACH requirements for safety data sheets, including extended sheets with exposure scenarios | 8. Exposure controls and personal protection |
| 29 CFR 1910.1200(g)(2) | Sheets updated within a defined period when significant new information becomes available | 16. Other information |
| 29 CFR 1910.1200(h) | Employee training on the sheet format and label elements | How this is used on our site |
What it does not cover
- The chemical risk assessment, which addresses your use rather than the substance.
- Workplace labelling, including secondary containers, which has its own requirements.
- The substance register, recording what is held and where.
- Exposure monitoring, measuring actual exposure against the limits the sheet reports.
- Waste and disposal documentation, governed by waste regulation.
Filling it in
Filling it in well
Hold the current sheet, read the sections that matter, and translate rather than distribute.
A sheet held for years may predate a reclassification, and suppliers are required to update sheets when significant new information becomes available. The 2024 alignment with GHS Revision 7 changes content in several sections, with compliance dates running into 2026 for substances and 2028 for mixtures, so revised sheets will continue arriving through that period.
Section 2 gives the hazard classification and label elements. Section 7 covers handling and storage, including incompatibilities. Section 8 gives exposure limits and control measures, and those limits are what any monitoring result is compared against. These three carry most of what a site actually needs; the remainder is largely for responders and regulators.
Stability and reactivity, including incompatible materials, is what determines what can be stored next to what. Segregation decisions made on the basis of container size or convenience, rather than on incompatibility, are a common cause of reactions during spills and fires.
The output people need at the point of use is short: what to wear for this task, what to do if it spills, what it must not touch, and what to do if someone is exposed. Distributing a sixteen-section document to an operator is a filing action; producing a task-level instruction from it is hazard communication.
Audit findings
Common audit findings
Findings here concentrate on currency, accessibility and the gap between the sheet and the task.
| Finding | Clause | What fixes it |
|---|---|---|
| Sheets held but not current after a supplier reissue. | 1910.1200(g)(2) | Suppliers must update on significant new information; check currency on receipt of each delivery. |
| Sheets not readily accessible to employees in the work area. | 1910.1200(g)(8) | Accessible during each shift and in the area, not in a manager's office. |
| Sheet treated as satisfying the risk assessment requirement. | COSHH reg.6 | The sheet describes the substance; the assessment describes your exposure. |
| Section 8 exposure limits not used in the assessment or monitoring. | 1910.1200 App D | These are the figures measured exposure is compared against. |
| Incompatibility in section 10 not reflected in storage segregation. | 1910.1200 App D | Segregate by incompatibility rather than by container or convenience. |
| Employees not trained on the sheet format after the 2024 changes. | 1910.1200(h) | The format and label elements changed; training obligations follow. |
| Substances on site with no sheet at all. | 1910.1200(g)(1) | Usually arrives via maintenance or contractors; control the entry route. |
| Sheet content not translated into task-level instruction. | 1910.1200(h) | Distributing the document is filing; producing usable instruction is communication. |
| Reliance on a sheet from a different supplier for the same generic product. | 1910.1200(g) | Formulations differ; the sheet must match the product actually supplied. |
| No process for reviewing what a reissued sheet changed. | 1910.1200(g)(2) | A reissue may reclassify; compare rather than replace silently. |
Worked case
Case in point: the sheet that arrived and changed nothing
A supplier reissued the safety data sheet for a cleaning chemical following a reclassification. The new sheet arrived by email, was saved over the previous version in the shared folder, and the folder was noted as current at the next audit.
The reclassification had added a skin sensitisation hazard. The chemical risk assessment for the task, the glove specification, the health surveillance decision and the training content had all been built on the previous classification and none were revisited.
Nothing in the site's process compared the new sheet against the old one. Replacing a document is an administrative act, and it had been performed correctly.
Definitions
Definitions and key terms
- Safety data sheet
- The supplier document following a sixteen-section harmonised format describing a hazardous chemical.
- GHS
- The UN Globally Harmonized System of classification and labelling, to which national regimes align.
- Section 8
- Exposure controls and personal protection, containing the exposure limits monitoring is compared against.
- Section 10
- Stability and reactivity, including incompatible materials, which governs storage segregation.
- Extended safety data sheet
- An EU sheet with exposure scenarios attached, produced under REACH above a tonnage threshold.
- Trade secret claim
- Withholding exact composition, now requiring a prescribed concentration range to be disclosed instead.
- Reclassification
- A change in a substance's hazard classification, communicated through a reissued sheet.
- Secondary container labelling
- Workplace labelling of decanted product, a separate requirement the sheet informs.
FAQ
Frequently asked questions
Which sections actually matter operationally?+
Sections 2, 7 and 8. Section 2 gives the hazard classification and label elements, section 7 covers handling and storage including incompatibilities, and section 8 gives exposure limits and controls. Section 10 matters for storage segregation. The remainder is largely for emergency responders, regulators and transport, and it is still required to be present.
Is holding the sheets enough?+
No. Sheets must be obtained, maintained current and readily accessible to employees during each shift in their work areas, and employees must be trained on the format. Beyond compliance, the sheet describes the substance in isolation and cannot tell anyone what to do in a specific task, which is what the risk assessment produces.
What changed with the 2024 alignment?+
OSHA's final rule aligned the Hazard Communication Standard with GHS Revision 7, changing content in several sections including hazard identification, composition, physical properties and toxicology, and requiring concentration ranges where composition is claimed as a trade secret. Compliance dates were extended by four months in January 2026 and run into 2026 for substances and 2028 for mixtures.
What should happen when a sheet is reissued?+
Compare it against the version it replaces. Sheets are reissued because something changed, and a reclassification can affect the risk assessment, the PPE specification, health surveillance and training. Saving the new file over the old one is administratively correct and destroys the only record of what moved.
Can we use a sheet from a different supplier?+
No. Formulations differ between suppliers even for products with the same generic description, and the sheet must correspond to the product actually supplied. This becomes a live issue where purchasing switches supplier on price for a like-for-like product, which is precisely the change least likely to be flagged as a chemical safety event.
The agents
What the agents do with it
The sheet is a supplier document. What fails is treating it as an assessment and replacing it without reading what changed.
Holds current sheets against the substance register, flags reissues for comparison against the previous version, and keeps them accessible at the point of use.
Watches supplier changes for formulation differences and raises assessment review when a reclassification appears in a reissued sheet.
Carries section 8 exposure limits into monitoring and surveillance decisions rather than leaving them in the document.
Delivers training on the sheet format and label elements, which the 2024 alignment made a live obligation again.
This template lives in KnowSafe — safety and compliance. Incidents, hazards, permits, inspections and the critical controls behind them.
Meet KnowSafe→Sources
Sources
- 29 CFR 1910.1200 and Appendix D, safety data sheets, OSHA
- OSHA final rule aligning the Hazard Communication Standard with GHS Revision 7
- HCS 2024 compliance date extension notice, OSHA
- WHMIS 2015, Hazardous Products Regulations (Canada)
- Regulation (EC) 1907/2006 Annex II, requirements for safety data sheets (EU)