Creating a safety data sheet (SDS) requires following a strict 16-section format established by OSHA’s Hazard Communication Standard, which aligns with the Globally Harmonized System (GHS) for classifying and labeling chemicals. The process involves gathering detailed chemical data, classifying your product’s hazards, and presenting everything in the correct order. Getting it wrong carries real consequences: OSHA can fine up to $16,550 per serious violation, or $165,514 for willful or repeated violations.
Who Needs To Create an SDS
If you manufacture, import, or distribute a chemical product classified as hazardous, you’re responsible for creating and providing an SDS. This applies to any chemical that poses a physical hazard (like flammability or explosivity), a health hazard (like toxicity or carcinogenicity), or falls into categories such as simple asphyxiants, combustible dusts, or pyrophoric gases.
There are exemptions. Consumer products used in a workplace the same way a typical consumer would use them, with no greater frequency or duration of exposure, don’t require an SDS. The exemption hinges on how the product is actually used at the worksite, not on how the manufacturer intended it. If employees use a consumer cleaning spray all day long in an industrial setting, that product still needs an SDS. Finished “articles” that don’t release hazardous chemicals under normal use, like a plastic chair or a sealed battery, are also generally exempt.
Step 1: Gather Your Chemical Data
Before you can write anything, you need a complete profile of your product. This is the most time-intensive part of the process, and skipping it leads to inaccurate or incomplete sheets. Start with these essentials:
- Chemical identity: Every ingredient’s chemical name, common synonyms, and CAS (Chemical Abstracts Service) number. For mixtures, you’ll need the concentration of each component.
- Physical and chemical properties: Appearance, color, form, odor, pH, flash point, boiling point, melting point, vapor pressure, solubility, and flammability. Flash point only applies to liquids. pH is typically relevant only for liquids or solutions. Viscosity matters specifically for determining aspiration toxicity.
- Toxicological data: LD50 and LC50 values (the dose or concentration lethal to 50% of test animals), routes of exposure, acute and delayed symptoms, and any carcinogenicity listings from NTP, IARC, or OSHA.
- Ecological data: Aquatic toxicity, biodegradability, bioaccumulation potential, and soil mobility.
- Regulatory and transport data: UN numbers, proper shipping names, hazard classes, packing groups, and any applicable regulations beyond OSHA.
For toxicological and ecological data, the European Chemicals Agency (ECHA) database and PubChem are widely used sources. If you’re working with a mixture, you may need to calculate hazard classifications based on ingredient data rather than testing the final product directly. When you rely on ingredient-level data rather than product-level testing, note that clearly on the SDS.
Step 2: Classify Your Product’s Hazards
Hazard classification is the backbone of your SDS. It determines everything from the signal word on your label to the protective equipment you recommend. OSHA’s Hazard Communication Standard defines two broad groups of hazards, each broken into classes and categories.
Health hazard classes include acute toxicity, skin corrosion and irritation, serious eye damage, respiratory or skin sensitization, germ cell mutagenicity, carcinogenicity, reproductive toxicity, specific target organ toxicity (from single or repeated exposure), and aspiration hazard. Physical hazard classes cover explosives, flammable gases, liquids, solids and aerosols, oxidizing gases, liquids and solids, gases under pressure, self-reactive chemicals, pyrophoric materials, self-heating chemicals, chemicals that emit flammable gas on contact with water, organic peroxides, corrosion to metals, and combustible dusts.
Each class has numbered categories, with Category 1 generally being the most severe. For example, flammable liquids range from Category 1 (flash point below 23°C and boiling point at or below 35°C) to Category 4 (flash point between 60°C and 93°C). You assign categories by comparing your product’s data against the threshold criteria spelled out in Appendices A and B of 29 CFR 1910.1200. For mixtures, you can often apply calculation methods that use ingredient concentrations and their individual hazard classifications to derive the mixture’s overall classification.
Step 3: Write the 16 Sections in Order
OSHA requires a fixed 16-section format. You cannot rearrange, rename, or omit sections. Here’s what goes into each one.
Sections 1 Through 8: Core Safety Information
Section 1, Identification: Your product name (matching the label), your company name, address, phone number, an emergency contact number, and the product’s recommended and restricted uses.
Section 2, Hazard Identification: This is where your classification work pays off. List the hazard classification, the signal word (“Danger” or “Warning”), all applicable GHS pictograms, hazard statements, and precautionary statements. If any ingredients have unknown acute toxicity, state the percentage.
Section 3, Composition/Information on Ingredients: For single substances, include the chemical name, CAS number, and any impurities or stabilizing additives that contribute to the product’s hazard classification. For mixtures, list ingredients at or above their concentration cutoff for health hazards. Trade secret claims are allowed, but you still need to disclose the specific health effects.
Section 4, First-Aid Measures: Provide instructions organized by route of exposure: inhalation, skin contact, eye contact, and ingestion. Describe both immediate and delayed symptoms someone might experience, along with any notes for emergency medical responders.
Section 5, Fire-Fighting Measures: Specify which extinguishing agents work and which ones to avoid. Describe hazardous combustion products (toxic fumes, gases) and any special protective equipment firefighters should use.
Section 6, Accidental Release Measures: Cover personal precautions, protective equipment needs, emergency procedures, and specific containment and cleanup methods. Differentiate between small and large spills if the response differs.
Section 7, Handling and Storage: Describe safe handling practices, hygiene measures (like washing hands before eating), and storage conditions. Note incompatible materials that should never be stored nearby.
Section 8, Exposure Controls/Personal Protection: Include occupational exposure limits (OSHA permissible exposure limits and ACGIH threshold limit values), recommended engineering controls like ventilation, and specific PPE: glove type, respirator type, eye protection, and protective clothing.
Sections 9 Through 11: Technical and Health Data
Section 9, Physical and Chemical Properties: List measurable properties like appearance, odor, odor threshold, pH, melting point, boiling point, flash point, evaporation rate, flammability, vapor pressure, vapor density, specific gravity, solubility, partition coefficient, auto-ignition temperature, decomposition temperature, and viscosity. Always include the color and physical form. Leave fields marked “not applicable” or “no data available” rather than blank.
Section 10, Stability and Reactivity: State whether the chemical is stable under normal conditions. Identify hazardous reactions that could occur, conditions to avoid (heat, light, moisture), incompatible materials, and any hazardous decomposition products.
Section 11, Toxicological Information: Describe likely routes of exposure and the symptoms associated with each. Include numerical toxicity measures like LD50 (oral, dermal) and LC50 (inhalation). Note whether the substance appears on carcinogen lists maintained by NTP, IARC, or OSHA, and describe any chronic health effects from repeated exposure.
Sections 12 Through 16: Supplementary Information
Sections 12 through 15 are required in the document’s structure, but OSHA does not enforce their content. Other regulatory bodies, particularly the EPA and international agencies, do use this information.
Section 12, Ecological Information: Aquatic toxicity data, persistence and degradability, bioaccumulation potential, and soil mobility. Section 13, Disposal Considerations: Appropriate disposal methods, container handling, and relevant waste codes. Section 14, Transport Information: UN number, proper shipping name, transport hazard class, packing group, and whether the substance is a marine pollutant. Section 15, Regulatory Information: Any safety, health, or environmental regulations specific to the product that aren’t covered elsewhere.
Section 16, Other Information: The date of preparation or last revision, and any additional information you consider useful, such as a revision history or references.
Keeping Your SDS Current
An SDS is not a one-time document. OSHA requires you to revise it within three months of becoming aware of significant new information about a chemical’s hazards. This includes new toxicity data, changes in composition, updated exposure limits, or reclassification of a hazard. Even without new hazard information, reviewing your SDS periodically (every three to five years is a common industry practice) helps catch outdated regulatory references or exposure limits.
The GHS itself is updated on a two-year cycle. The most recent version is Revision 11, published in 2025. OSHA doesn’t automatically adopt every new GHS revision, so watch for rulemaking updates that incorporate newer classification criteria or label elements.
SDS Authoring Software
You can write an SDS manually using a word processor, but most companies producing more than a handful of sheets use dedicated authoring software. These tools typically offer pre-built phrase libraries aligned with GHS language, automated hazard classification based on ingredient data, regulatory database cross-referencing, and multi-language translation. Many also generate related compliance reports, manage approval workflows, and let you distribute SDS documents digitally through QR codes or mobile-accessible portals.
The main advantage of software is consistency. When exposure limits change or a new regulation takes effect, a good platform can flag every affected SDS in your library for review rather than requiring you to hunt through files manually. For companies managing products across multiple countries, some tools handle region-specific regulatory requirements, automatically adjusting content to meet local variations of GHS implementation.
If your volume is low, OSHA’s published SDS format guidance and freely available templates can get you started without a software investment. The critical thing is accuracy, not the tool you use to produce the document.