/ IN THIS BLOG
SDS’s, or Safety Data Sheets, are critical safety documents designed to bridge the gap between complex chemical science and everyday workplace safety when hazardous chemicals are used within a business.
Rather than being a simple “ingredient list,” SDS sheets provide a safety manual for workers that highlight potential hazards, providing the key information necessary to prevent accidents from occurring and quickly deliver an actionable playbook if something does go wrong.
Because there have been numerous changes to Occupational Safety and Health Administration (OSHA) protocols over the last two decades in terms of documentation, it’s important to understand what is required now. This is not only with a goal in mind of remaining compliant, but also providing the most comprehensive data to keep everyone safe around hazardous chemicals.
01 / MSDS vs SDS: What Changed and Why
If your organization has handled chemicals for a long time, you may still hear the term MSDS used interchangeably with SDS. Understanding MSDS vs SDS is important, because they are not interchangeable. The switch to SDS reflected a major shift in how chemical safety information is standardized and communicated.
Under the old system, manufacturers were required to provide safety information, but there was no single required format. That meant MSDS documents could vary widely in structure, terminology, and level of detail. Finding critical information during an emergency often required scanning multiple pages or interpreting inconsistent layouts.
In 2012, OSHA officially replaced MSDS with Safety Data Sheets (SDS) as part of a major update to its Hazard Communication Standard (HCS). This update brought the US in line with globally recognized standards, an important step for importing and exporting materials. SDS’s follow a standardized 16-section format, making it easier for workers, supervisors, and emergency responders to quickly locate key information regardless of who manufactured the chemical.
This standardization improves readability and reduces confusion when handling and storing chemicals. There was no required order in MSDS sheets, so first aid might be on page 1 of one document and page 6 of another. SDS standardization supports faster decision-making during spills, exposures, or fires because the information can always be found in the same place.
While older MSDS documents may still exist in legacy systems, OSHA requires that current chemicals be supported by compliant SDS’s. Despite it being over a decade since the change occurred, the MSDS term still pops up occasionally, although from a compliance perspective regarding hazardous chemicals, it’s essentially obsolete.
Material Safety Data Sheets or MSDS used to be a common term across manufacturing and other industries. Because legacy labeling may slip through the cracks, when auditing your facility’s documents, it’s important to make certain that document storage is properly labeled. For example, double check that all "MSDS Binders" are updated to "SDS Binders." It’s important to review that every document inside has been updated by the manufacturer to the 16-section SDS format.
02 / Why SDS’s Are a Core Part of Chemical Safety Documentation
SDS’s play a critical role in how organizations safely manage chemicals in the workplace. Whether a facility manufactures, stores, transports, or uses chemicals as part of daily operations, these documents provide essential information that helps protect employees, emergency responders, and the environment.
What are SDS’s?
Short for Safety Data Sheets, SDS’s are standardized documents required under OSHA regulations. They communicate the hazards associated with a chemical and explain how it should be handled, stored, and disposed of safely. In the event of a spill, exposure, or fire, SDS’s are often the first resource referenced to determine appropriate response measures.
Because chemicals and formulations change over time, SDS’s are not static paperwork. They are living compliance tools that must be accurate, accessible, and up to date. Missing or outdated SDS’s can delay emergency response, increase injury risk, and lead to regulatory violations during inspections.
03 / SDS Requirements
Safety Data Sheets required by OSHA consist of a predictable 16-section layout to improve safety and align with global hazard communication standards. SDS requirements include that the standardized 16-section format follow this specific order:
1. Identification:
Product name, manufacturer info, and emergency contact.
2. Hazard(s) Identification:
Pictograms, signal words, and specific hazard statements.
3. Composition/Information on Ingredients:
Chemical names, identifiers, and concentrations.
4. First-Aid Measures:
Initial care and symptoms of exposure.
5. Fire-Fighting Measures:
Recommended extinguishing methods and specific hazards.
6. Accidental Release Measures:
Containment and cleanup procedures.
7. Handling and Storage:
Safe use practices and incompatible storage conditions.
8. Exposure Controls/Personal Protection:
Exposure limits (PELs/TLVs) and required PPE.
9. Physical and Chemical Properties:
Appearance, pH, flash point, and now particle size for solids.
10. Stability and Reactivity:
Incompatible materials and hazardous reactions.
11. Toxicological Information:
Routes of exposure and related health effects.
12. Ecological Information:
Environmental impact (non-mandatory for OSHA).
13. Disposal Considerations:
Waste handling guidance (non-mandatory).
14. Transport Information:
UN number and shipping details (non-mandatory).
15. Regulatory Information:
Safety and environmental regulations (non-mandatory).
16. Other Information:
Date of preparation or last revision.
With each Safety Data Sheet detailing this information, it can consistently communicate the hazards, handling requirements, and emergency response information associated with a specific chemical. That consistency is especially important during emergencies, inspections, or employee training. SDS's are required for hazardous chemicals used or stored in the workplace and are a core component of safety data sheets OSHA regulations. For mixed chemicals, SDS’s list hazardous ingredients and their concentrations so risks can be accurately assessed.
04 / New SDS Requirements Under OSHA: What You Need to Know About Changes to Chemical Safety Documentation
In 2024, OSHA released another major update to its HCS to remain up-to-date with the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) Revision 7.
SDS's remain a requirement, but there are several key changes which will be going into effect over the next few years.
SDS Content Updates:
Section 2: This section must now include hazards resulting from "reasonably anticipated downstream uses" and chemical reactions.
Section 3: Trade secret rules are revised. Manufacturers claiming a secret concentration must now disclose a prescribed concentration range.
Section 9: Now requires specific particle characteristics (like size) for solids.
New Hazard Classes: New categories have been added for aerosols, desensitized explosives, and chemicals under pressure.
Small Container Labeling: New, flexible labeling rules for small (≤100ml) and very small (≤3ml) containers allow for abbreviated information on the immediate container if the full label is on the outer packaging.
Bulk Shipment: Labels for bulk shipments can now be transmitted via shipping papers or electronically rather than being physically attached to the container.
Adopting these new disclosure requirements and ensuring the chemicals you handle are properly classified under these updated ranges is a complex process where expert guidance is highly recommended.
05 / Best Practices for SDS's
One of the most important SDS requirements is accessibility. SDS's must be readily available to employees during their work shifts, without barriers. This means workers should not have to request permission, search through locked files, or wait for a supervisor to access chemical safety information.
Many organizations meet this requirement by maintaining electronic SDS systems, provided employees are trained on how to access them. However, to remain fully compliant with the OSHA HCS, your facility must maintain a back-up plan, such as a hardcopy physical binder of SDS's or battery-powered backed-up server. These back-up measures ensure access to SDS's in the event there is a power outage or network failure.
Accuracy and currency are equally critical. SDS's must reflect the current formulation of the chemical being used. If a product’s composition changes or a new hazard is identified, the SDS must be updated accordingly. Relying on outdated sheets can lead to improper handling, incorrect emergency response, and compliance violations.
Inspectors frequently review SDS's during audits because they are a foundational piece of chemical safety documentation. Missing SDS's, incomplete records, or inaccessible systems are common findings during inspections and can result in citations or fines. Understanding and meeting SDS requirements helps organizations create safer work environments while demonstrating clear compliance with chemical safety regulations.
06 / How to Obtain and Manage SDS's
SDS’s are typically provided by the chemical manufacturer or distributor. Under OSHA regulations, suppliers are required to make SDS's available at or before the time a chemical is shipped. If an SDS is missing or incomplete, facilities should contact the supplier directly to request an updated version.
Managing SDS’s effectively is just as important as obtaining them and facility managers should make sure they are following proper handling steps:
SDS’s should be organized, accessible, and easy for employees to locate when needed. Electronic SDS’s can simplify updates and improve access across multiple departments or locations. Electronic systems are acceptable as long as employees know how to use them, sheets can be accessed without delay, and there is a back-up system in place.
Regular reviews of chemical inventories should include removing outdated products and confirming that SDS’s match the chemicals currently in use.
When new chemicals are introduced, corresponding SDS's should be added immediately to the system and communicated to staff as part of hazard communication training.
Treating SDS’s as active chemical safety documentation, not static files, helps facilities stay compliant and prepared. Proper management ensures employees have reliable information at their fingertips and reduces the risk of compliance issues during inspections.
07 / SDS’s, Waste Handling, and Disposal
SDS’s do more than describe chemical hazards, they also inform how chemicals should be handled once they become waste. Information found in SDS's helps determine appropriate storage conditions, compatibility concerns, and recommended disposal methods, all of which are critical for safe and compliant waste management.
When chemicals are no longer usable, SDS's provide guidance on whether the material is flammable, corrosive, toxic, or reactive. This information supports proper segregation and prevents incompatible materials from being mixed during storage or disposal. It also helps facilities identify special handling requirements, such as temperature controls or protective equipment, before waste is removed.
Accurate SDS’s are especially important when chemical formulations change. Even small changes can affect how waste should be managed. Relying on outdated SDS’s can lead to improper disposal practices or increased risk during spills and cleanup activities.
By keeping SDS’s current and accessible, organizations strengthen their overall chemical safety documentation and support safer waste handling decisions from initial use through final disposal.
08 / Change Is Constant: Partnering With an Expert In Chemical and Hazardous Waste Management
As is evident, chemical safety regulations continue to evolve and SDS’s are no exception. As formulations change, standards update, and new chemicals are introduced into the workplace, keeping chemical safety documentation accurate and compliant requires ongoing attention. For many facilities, managing SDS requirements internally can become time-consuming and easy to overlook amid daily operations.
MCF Environmental Services provides the waste management experience facilities trust to remain safe and compliant, while reducing the burden on staff. We can help you support proper SDS management by identifying gaps in documentation and ensuring safety data sheets align with current regulatory requirements. This guidance is especially valuable for organizations handling a wide range of chemicals or operating across multiple locations.
By staying current with safety data sheets, OSHA requirements and related regulations, organizations are better positioned to respond to incidents, pass inspections, and protect employees.
MCF works alongside facilities to help simplify chemical safety documentation and waste management, offering expertise that adapts as regulations change. With the right support, your SDS’s can become a reliable part of a broader, well-managed safety program rather than an ongoing compliance concern. Reach out today to get the process started.
Robert Losurdo
