1. Definition in one paragraph
An SDS is a 16-section technical document written by the manufacturer, importer or distributor of a chemical. It answers, in a fixed order, four questions any user needs to work safely: What is this substance? What can it do to me, to others, and to the environment? What do I do if things go wrong? What are the legal constraints on how I ship, store and dispose of it? The 16-section skeleton is set by UN GHS Rev. 10 (2023) and reproduced verbatim in national law.
2. Why the SDS exists
Before GHS, every country used its own format. A drum of acetone shipped from Germany to Texas arrived with three different data sheets, three different pictograms and no shared vocabulary. A safety manager reading a Japanese MSDS in Ohio had to translate not only the language but the classification system. Fatal accidents — most famously the Bhopal disaster in 1984 — proved the cost of that fragmentation.
The UN adopted GHS in 2003 and countries progressively transposed it into national law. OSHA published HazCom 2012 (the "GHS update"), the EU published Regulation (EC) 1272/2008 (CLP), and the same sixteen sections, the same nine pictograms and the same H-statements are now used from Osaka to Ohio to Oslo.
3. The 16 SDS sections
The order is fixed by law — never reshuffle. The first eight sections are for the person using the chemical; sections 9–11 are for technical and safety specialists; sections 12–16 are for regulators and shippers.
| # | Section | Who reads it | EU/US |
|---|---|---|---|
| 1 | Identification of the substance and supplier | Everyone | Both |
| 2 | Hazards identification (GHS class, pictograms, signal word, H/P statements) | Everyone | Both |
| 3 | Composition / information on ingredients | Chemist, EHS | Both |
| 4 | First-aid measures | Everyone, first responders | Both |
| 5 | Fire-fighting measures | Fire brigade, EHS | Both |
| 6 | Accidental release measures (spill response) | EHS, on-site staff | Both |
| 7 | Handling and storage | Operators, warehouse | Both |
| 8 | Exposure controls / personal protection (PEL, TLV, PPE) | EHS, occupational hygienist | Both |
| 9 | Physical and chemical properties | Process engineer | Both |
| 10 | Stability and reactivity | Chemist, process safety | Both |
| 11 | Toxicological information (LD50, target organs, carcinogenicity) | Toxicologist, medical | Both |
| 12 | Ecological information (aquatic toxicity, persistence, bioaccumulation) | Environmental engineer | EU only |
| 13 | Disposal considerations (waste codes) | Waste manager | EU only |
| 14 | Transport information (UN number, class, packing group, ADR/IMDG/IATA) | Shipping, DGSA | Both |
| 15 | Regulatory information (REACH, TSCA, national inventories) | Regulatory affairs | EU only |
| 16 | Other information (revision date, abbreviations, references) | Everyone | Both |
Each section has strict sub-headings. A deep-dive walkthrough with real examples lives at the 16 sections explained, and Section 8 (PPE, exposure limits) has its own dedicated guide at SDS Section 8.
4. OSHA HazCom 2012 vs EU CLP/REACH
Both regimes require the same 16-section skeleton and the same GHS pictograms. They diverge on which sections are mandatory and on which extra data must accompany the sheet:
| Topic | United States (OSHA HazCom 2012) | European Union (CLP + REACH) |
|---|---|---|
| Legal basis | OSHA 29 CFR 1910.1200 (HazCom 2012) | Regulation (EC) 1272/2008 (CLP) + Regulation (EC) 1907/2006 (REACH), Annex II |
| Sections 12–13, 15 mandatory? | Non-mandatory (may be blank) | Mandatory (fines up to €50k per missing section) |
| Language | English required; other languages optional | Official language(s) of every member state where the product is placed on the market |
| Exposure limits | OSHA PEL (often decades old), voluntary ACGIH TLV | Binding OELVs (Directive 2004/37/EC), plus national OELs |
| Extra REACH obligations | None | Registration number, exposure scenarios for identified uses, PBT/vPvB assessment, safe-use annexes |
| Retention | 30 years (exposure records, 29 CFR 1910.1020) | 10 years after last supply (REACH Article 36) |
| Consumer products | Exempt if used in normal consumer quantities | Retail label enough; SDS on request under REACH Art. 32 |
If you import into the EU you cannot re-use a US SDS as-is: you need an EU version with REACH registration numbers, exposure scenarios for identified uses, and the local language of every member state where the product is placed on the market.
5. Who must provide an SDS
The manufacturer, importer or distributor of any classified hazardous chemical must:
- Provide the SDS free of charge — never behind a paywall or a login for downstream users.
- Provide it in the official language(s) of every country where the product is sold.
- Provide it at or before the first delivery, and immediately whenever the classification changes.
- Keep the SDS available throughout the supply chain, so a wholesaler must pass it to the retailer, and the retailer to the professional buyer.
There is no obligation to hand an SDS to a retail consumer for products used in domestic quantities (a bottle of bleach in a supermarket). The pictogram label on the bottle is enough. But as soon as an employer buys that same bleach for professional cleaning, an SDS must be obtained.
6. Who must keep one
Every employer whose staff can be exposed to the chemical must keep the SDS accessible during every work shift. Under OSHA 1910.1200(g)(8), "accessible" means the employee can consult the sheet without asking anyone — a locked office or a supervisor's laptop does not count. Acceptable formats:
- A paper binder in the work area.
- An intranet page reachable from a workshop computer.
- A QR code on the drum linking to the manufacturer's PDF.
- A dedicated SDS management system (SAP EHS, Chemwatch, VelocityEHS, etc.).
In the EU, Article 35 of REACH extends the right of access to workers' representatives. In addition, an employer must integrate SDS content into the workplace chemical risk assessment (Directive 98/24/EC).
7. How to read an SDS in 60 seconds
Nobody reads an SDS cover-to-cover before opening a bottle. The trick is to jump to four sections in a fixed order:
- Section 2 — Hazards. Look at the pictograms and the signal word. Danger + flame = flammable, act accordingly. See our GHS pictogram guide and the signal words explainer.
- Section 4 — First aid. Know the response before you open the container. "In case of eye contact, rinse for 15 minutes" is useless information after the splash.
- Section 7 & 8 — Handling, storage, PPE. Do you have the right gloves? Nitrile is not butyl. Is the storage cabinet cool and vented?
- Section 10 — Reactivity. What must never touch this substance? Mixing bleach and ammonia is the textbook example — see our chemical compatibility guide.
8. Updates and retention
The supplier must revise the SDS without delay when new hazard, classification or precautionary information becomes available (new GHS category, new REACH restriction, new exposure limit). "Without delay" is interpreted as 30 days in most EU jurisdictions.
Retention rules differ:
- OSHA (US) — employers must keep exposure records for 30 years after the last exposure (29 CFR 1910.1020). SDSs relevant to that exposure count as part of the record.
- REACH (EU) — suppliers must archive the SDS for at least 10 years after the last supply of the substance or mixture (Article 36).
- Best practice — keep both current and superseded versions, because a lawsuit over an exposure that happened 20 years ago will demand the SDS that was in force then, not the one on file today.
9. Common mistakes that fail an audit
- Using the manufacturer's SDS for a re-labelled or diluted product. Once you dilute, mix or re-package, you become the supplier and must issue your own SDS.
- Keeping only English SDSs in a multilingual site. CLP requires the local language of the country where the product is used.
- Trusting an SDS older than 3 years. Classifications change; a 2015 SDS may reference GHS Rev. 5 and miss reproductive toxicity categories introduced later.
- Storing SDSs on a personal cloud drive. If the account holder leaves, workers lose access — automatic non-compliance.
- Confusing an SDS with a Certificate of Analysis (CoA). A CoA reports batch purity; an SDS reports hazards. They are not interchangeable.