How to Create a Safety Data Sheet for OSHA Compliance

A Safety Data Sheet (SDS) conveys hazard information and safety recommendations for chemical substances and mixtures. This detailed document ensures that workers, emergency responders, and users are fully informed about the potential risks associated with a product. Creating an accurate SDS is an important element of maintaining a safe working environment. The process requires meticulous collection of scientific data and precise adherence to established international formatting requirements so that complex chemical information is accessible and actionable.

Understanding the Legal Framework and Required Structure

The requirement to produce an SDS stems from regulatory frameworks designed to standardize hazard communication. Globally, the foundation is the United Nations’ Globally Harmonized System of Classification and Labelling of Chemicals (GHS). In the United States, the Occupational Safety and Health Administration (OSHA) mandates compliance through its Hazard Communication Standard (HCS), specifically 29 CFR 1910.1200.

The HCS requires that every SDS follow a non-negotiable 16-section format aligned with the GHS structure. This standardized layout ensures consistency and makes information predictable and easy to locate during routine operations or emergencies. The sections are logically grouped, starting with general identification and immediate safety measures, moving into operational controls and physical properties, and concluding with technical, toxicological, and regulatory requirements.

Initial Steps: Data Collection and Hazard Classification

The foundational step involves comprehensive data collection regarding the chemical product and its components. This includes gathering supplier safety data sheets for all ingredients, existing testing results, stability reports, and toxicological studies. If the product is a mixture, the identity and concentration of every ingredient must be documented to determine the final hazard profile.

The next step is Hazard Classification, which applies the GHS criteria to the gathered data. This scientific process evaluates the substance or mixture against GHS endpoints for physical hazards (e.g., flammability or explosiveness) and health hazards (e.g., carcinogenicity or acute toxicity). The classification results dictate the appropriate signal word, pictogram, and hazard statements used in the document.

Drafting Core Safety Information (Sections 1 through 6)

The initial sections of the SDS provide the most immediate and necessary information to the user and emergency personnel.

Section 1: Identification

Section 1, Identification, establishes the product identifier, recommended uses, restrictions, and the contact details for the manufacturer or distributor. This ensures rapid communication if a problem arises, and must include an emergency phone number.

Section 2: Hazard(s) Identification

Section 2 presents the determined GHS classification, acting as the document’s warning label. This section must display the appropriate hazard pictograms, the signal word (Danger or Warning), and specific hazard statements detailing the nature of the risk. Precautionary statements, which describe recommended measures to minimize or prevent adverse effects, are also included here.

Section 3: Composition/Information on Ingredients

Section 3 discloses the chemical identity and concentrations of the components contributing to the hazard. This section clarifies which chemicals are responsible for the hazards listed in Section 2. This transparency is important for medical staff and industrial hygienists.

Sections 4 through 6: Emergency Response

Sections 4 through 6 address immediate response protocols for accidents and exposures.

Section 4, First-Aid Measures, provides specific instructions for all routes of exposure, detailing immediate care and noting any symptoms that may occur later.

Section 5, Fire-Fighting Measures, details appropriate extinguishing media (e.g., water fog or dry chemical) and identifies any special hazards that may arise during a fire, such as toxic decomposition products.

Section 6, Accidental Release Measures, gives clear directions for safely containing and cleaning up spills. This section outlines the required Personal Protective Equipment (PPE) for responders, methods for containment, and disposal procedures for the contaminated material.

Documenting Operational Controls and Physical Properties (Sections 7 through 9)

Sections 7 through 9 provide the information necessary for day-to-day safe operations and exposure management.

Section 7: Handling and Storage

Section 7 details safe practices necessary for day-to-day operations. This includes ventilation requirements, incompatible materials to avoid, and appropriate storage conditions. Storage conditions, such as temperature and humidity controls, are necessary to maintain product stability.

Section 8: Exposure Controls/Personal Protection

Section 8 focuses on protecting workers from chemical inhalation, ingestion, or contact. This section must list established exposure limits, such as OSHA Permissible Exposure Limits (PELs) and American Conference of Governmental Industrial Hygienists (ACGIH) Threshold Limit Values (TLVs). These values represent the maximum average concentration of a substance in the air to which a worker can be exposed over a specific period.

Based on the chemical’s hazards, Section 8 specifies required engineering controls, such as local exhaust ventilation, to minimize airborne concentrations. It also defines the necessary Personal Protective Equipment (PPE). This may include specific types of gloves, protective clothing, eye protection, and respirator requirements.

Section 9: Physical and Chemical Properties

Section 9 provides the characteristic data points of the substance. This includes numerical data such as pH, flash point, boiling point, and vapor pressure. Descriptive details like appearance and odor are also included. This data helps users understand the substance’s behavior and potential for fire or explosion.

Detailing Technical, Toxicological, and Environmental Data (Sections 10 through 12)

This group of sections delves into the substance’s technical characteristics and its long-term impact.

Section 10: Stability and Reactivity

Section 10 describes the conditions under which the product may become unstable or undergo hazardous chemical reactions. This includes listing incompatible materials, such as strong acids or oxidizers, and physical conditions, like excessive heat or shock, that should be avoided during handling and storage.

Section 11: Toxicological Information

Section 11 provides the health effects data used to classify the substance in Section 2. This section must describe all relevant routes of exposure, including inhalation, skin contact, and ingestion, and detail the symptoms associated with short-term, acute exposure. It also addresses delayed or long-term health effects, such as carcinogenicity, mutagenicity, and reproductive toxicity, citing relevant studies or regulatory lists.

Numerical measures of toxicity are presented here, such as the Median Lethal Dose (LD50) and the Median Lethal Concentration (LC50). These values represent the dose or concentration that is statistically expected to kill 50% of a test population, providing a quantitative measure of acute toxicity.

Section 12: Ecological Information

Section 12 addresses the potential impact of the substance if released into the environment. This section details environmental fate data, such as biodegradability and potential for bioaccumulation in organisms. It also includes ecotoxicity data, like toxicity to fish or aquatic invertebrates, allowing users to understand the substance’s persistence and potential for long-term ecological harm.

Completing Regulatory and Miscellaneous Requirements (Sections 13 through 16)

The final sections ensure compliance with disposal, transportation, and broader regulatory requirements.

Section 13: Disposal Considerations

Section 13 provides guidance on safe waste handling and disposal methods for the chemical and any contaminated packaging. This information directs the user to comply with all federal, state, and local waste regulations. Disposal must often be done through a licensed waste management company.

Section 14: Transport Information

Section 14 is important for supply chain compliance and worker safety during shipping. This section must provide the classifications required for domestic and international transport, including DOT, IMDG, and IATA regulations. Accurate completion requires listing the proper shipping name, UN number, hazard class, and any applicable packing group.

Section 15: Regulatory Information

Section 15 addresses specific national or regional chemical inventory requirements and other non-hazard regulations. For example, this section confirms the substance’s status under the Toxic Substances Control Act (TSCA) inventory in the United States or compliance with other global chemical control laws. This ensures the product is legally allowed to be manufactured, imported, or used in the target region.

Section 16: Other Information

Section 16 serves as the administrative section. It must include the date the SDS was prepared or the date of the last revision, which is important for version control. This section also provides the user with an explanation of any abbreviations or acronyms used throughout the document.

Review, Revision, and Distribution Standards

Administrative requirements follow the creation of the SDS to maintain its accuracy and accessibility. Manufacturers must establish a schedule for periodic review, often recommended every three years, or immediately when new hazard information becomes available. Maintaining an accurate revision date confirms that the document reflects the most current scientific understanding and regulatory requirements.

Federal standards mandate that the SDS be readily accessible to all employees in the workplace during their shift. Manufacturers and distributors also have a legal obligation to provide the current SDS to all downstream users, ensuring effective hazard communication throughout the supply chain.