Safety Data Sheet requirements

The SDS must list the product identifier, other names, recommended uses and restrictions, manufacturer/importer contact info, and an emergency phone number. Appendix D requires these items under Section 1: (a) product identifier; (b) other means of identification; (c) recommended use and restrictions; (d) name, U.S. address, and U.S. telephone number of the manufacturer, importer, or other responsible party; and (e) emergency phone number (Appendix D to 1910.1200—Safety Data Sheets (Mandatory)).

• Include an emergency phone number that works 24/7 or instructions for obtaining immediate assistance.
• If a chemical has common names or synonyms, list them so users can match label names to the SDS.

(See 1910.1200 App D.)

The SDS must present the chemical’s classification, required signal word, hazard statements, pictograms/symbols, precautionary statements, and any hazards not otherwise classified. Appendix D specifies that Section 2 must include the classification in accordance with 1910.1200(d)(1)(i), the signal word, hazard statements, symbol(s) and precautionary statements consistent with 1910.1200(f), plus hazards classified under 1910.1200(d)(1)(ii) and any other identified hazards (Appendix D to 1910.1200).

• If a mixture contains ingredients of unknown acute toxicity at ≥1% and the mixture isn't classified based on whole-mixture testing, Section 2 must state the percent of unknown acute toxicity ingredients (see Section 2(e) in Appendix D).
• Use the required signal words and hazard statements to be consistent with label and classification rules under 1910.1200.

For mixtures, the SDS must identify chemical names, CAS numbers or other unique identifiers, and either exact percentages or concentration ranges for all ingredients that are health hazards and above cut-off/concentration limits or present a health risk below cut-offs. Appendix D explains the composition requirements and the conditions for using concentration ranges or claiming trade secrets; when a trade secret is claimed you must include a statement that the specific identity or concentration has been withheld under 1910.1200(i) (Appendix D to 1910.1200).

• Exact percentages are required unless a valid trade secret claim is made, there is batch-to-batch variability, or the product is part of a group of substantially similar mixtures where ranges are appropriate.
• If a CAS number is not available or is claimed as a trade secret, the preparer must indicate the source of the unique identifier.

(See 1910.1200 App D and 1910.1200(i).)

When a trade secret claim withholds exact concentrations, the SDS must use the prescribed concentration ranges specified in 1910.1200(i)(1)(iv)-(vi) and the associated subsections (1910.1200(i)(1)(v) and 1910.1200(i)(1)(vi)). The regulation prescribes allowable ranges employers/preparers must use when concentration information is withheld as a trade secret (1910.1200(i)).

• Use the specific concentration-range categories from 1910.1200(i)(1)(iv)-(vi) on the SDS whenever the exact percentage or range is being withheld as a trade secret.

(See 1910.1200(i)).

The SDS must describe necessary first-aid measures by route of exposure, list the most important symptoms/effects (acute and delayed), and indicate when immediate medical attention or special treatment is needed. Appendix D requires Section 4 to include (a) first-aid measures for inhalation, skin and eye contact, and ingestion; (b) most important symptoms/effects, acute and delayed; and (c) indication of immediate medical attention and special treatment when necessary (Appendix D to 1910.1200).

• Be specific about signs to watch for after exposure and what to tell medical personnel.
• If antidotes or special procedures exist, note them clearly.

(See 1910.1200 App D.)

The boiling point used on the SDS must be determined by the methods specified in 1910.106(a)(5) when the boiling point is needed to determine appropriate flammable liquid storage container size and type. Appendix D explicitly notes that to determine the proper flammable liquid storage container size/type, the boiling point shall be determined by the methods in 1910.106(a)(5) and then listed on the SDS (Appendix D to 1910.1200; see 1910.106(a)(5)).

• Use the correct test method for boiling point if SDS information will affect storage classification and container choice under the flammable liquids rules.

(See 1910.106(a)(5) and 1910.1200 App D.)

No. Sections 12 through 15 are optional and may be included at the preparer’s discretion; sections 1–11 and 16 are mandatory. Appendix D explicitly states that an SDS shall include the information specified for sections 1–11 and 16, while Sections 12–15 may be included but are not mandatory (Appendix D to 1910.1200).

• Even though optional, including Sections 12–15 can help downstream users with transport, disposal, and environmental planning.

(See 1910.1200 App D.)

Section 8 must list OSHA permissible exposure limits (PELs), ACGIH Threshold Limit Values (TLVs), and any other exposure limits or ranges used or recommended by the preparer, plus appropriate engineering controls and individual protection measures. Appendix D specifies that Section 8 include (a) for all ingredients in Section 3 the OSHA PEL, ACGIH TLV, and any other exposure limits used or recommended where available; (b) appropriate engineering controls; and (c) individual protection measures such as PPE (Appendix D to 1910.1200).

• If a chemical has no PEL or TLV, indicate that none is established and list any recommended exposure limits.
• Be specific about necessary respirators, eye/skin protection, and engineering controls like local exhaust.

(See 1910.1200 App D.)

A chemical must be classified in accordance with the classification criteria in 1910.1200(d)(1)(i), and the SDS must report hazards classified under 1910.1200(d)(1)(ii) including any hazard classes and categories. In practice, that means preparers must evaluate the chemical against the Hazard Communication standard’s classification rules and then provide the resulting signal word, hazard statements, pictograms, and precautionary statements on Section 2 (1910.1200(d)(1)(i)-(ii)).

• Use the HCS criteria to determine category and class; do not invent custom hazard categories.
• Include any hazards that are ‘‘not otherwise classified’’ if identified during the classification process.

(See 1910.1200(d)(1)(i) and 1910.1200(d)(1)(ii).)

If a CAS number is not available or is claimed as a trade secret, the SDS preparer must indicate the source of the unique identifier and include a trade-secret statement per 1910.1200(i). Appendix D instructs that when a CAS number is not available or is withheld as a trade secret, the preparer must still provide an identifying unique identifier and note its source, and must follow the trade secret procedures in 1910.1200(i) (Appendix D to 1910.1200).

• Include a clear statement on the SDS that identity or concentration is withheld as a trade secret and follow the prescribed concentration-range rules if applicable.

(See 1910.1200 App D and 1910.1200(i).)

If an ingredient with unknown acute toxicity is used in a mixture at a concentration of ≥1% and the mixture is not classified based on whole‑mixture testing, the SDS must state the percent of the mixture made up of ingredient(s) of unknown acute toxicity. Appendix D Section 2(e) requires that statement whenever those conditions apply (Appendix D to 1910.1200).

• This helps downstream users assess acute toxicity risk when ingredient toxicity is unknown.
• If such ingredients are below 1% or the mixture is classified by whole‑mixture data, the statement is not required.

(See 1910.1200 App D.)

The SDS must state whether the hazardous chemical is listed in the National Toxicology Program (NTP) Report on Carcinogens, in the International Agency for Research on Cancer (IARC) Monographs, or has been found to be a potential carcinogen by OSHA. Appendix D Section 11(f) specifically requires identification of whether the chemical appears on NTP, IARC, or OSHA carcinogen lists, along with other toxicological data such as routes of exposure, symptoms, acute and chronic effects, and numerical toxicity measures (Appendix D to 1910.1200).

• If specific chemical data aren’t available, the preparer must say if alternative information was used and describe the method (e.g., SAR) per Appendix D.

(See 1910.1200 App D.)

The SDS must include the date of preparation of the SDS or the date of the last revision. Appendix D requires Section 16 to provide the date of preparation or last revision so users know how current the safety information is (Appendix D to 1910.1200).

• If the SDS has been updated for new hazard information, note the revision date and summarize the changes if practical.

(See 1910.1200 App D.)

No. Preparers must include all specified information within each required section, but they are not required to present that information in any particular order within a section. Appendix D states that while each section must contain all specified information, preparers are not required to present the information in any particular order within each section (Appendix D to 1910.1200).

• The critical requirement is that all required subheadings and content are present and clearly labeled; internal ordering flexibility is permitted.

(See 1910.1200 App D.)

The SDS must include a clear statement that the specific chemical identity or concentration (exact or range) has been withheld as a trade secret in accordance with [1910.1200(i)], and, when concentration ranges are withheld, use the prescribed concentration ranges in [1910.1200(i)(1)(iv)-(vi)]. Appendix D directs that where a trade secret is claimed the SDS must state that specific identity or concentration has been withheld as a trade secret and follow the trade secret provisions in 1910.1200(i) (Appendix D to 1910.1200).

• Provide the trade‑secret statement in Section 3 and use the legally prescribed concentration range categories when exact values are withheld.
• Maintain documentation supporting the trade-secret claim as required by [1910.1200(i)].

(See 1910.1200(i) and 1910.1200 App D.)

The SDS must explicitly indicate that no applicable information is available for that subheading. Appendix D requires that if no relevant information is found for a given subheading within a section, the SDS shall clearly indicate that no applicable information is available (Appendix D to 1910.1200).

• Use a clear phrase such as "No information available" for transparency so users know the preparer considered the subheading.

(See 1910.1200 App D.)

Yes. Section 8 must include for all ingredients or constituents listed in Section 3 the OSHA PEL, ACGIH TLV, and any other exposure limits or ranges used or recommended by the chemical preparer when available. Appendix D requires Section 8(a) to provide these exposure limits for each ingredient listed in Section 3 (Appendix D to 1910.1200).

• If a PEL or TLV does not exist for an ingredient, state that none is established and provide any recommended limits.

(See 1910.1200 App D.)

The SDS must list suitable and unsuitable extinguishing media, specific hazards from the chemical (including hazardous combustion products), and special protective equipment and precautions for firefighters. Appendix D Section 5 requires (a) suitable (and unsuitable) extinguishing media; (b) specific hazards arising from the chemical (e.g., hazardous combustion products); and (c) special protective equipment and precautions for firefighters (Appendix D to 1910.1200).

• Include guidance on whether water can be used, whether the chemical may produce toxic gases when burning, and recommended firefighter PPE and breathing apparatus.

(See 1910.1200 App D and 1910.106 where flammable-liquid storage issues may apply.)

Section 6 must describe personal precautions and protective equipment, emergency procedures, and appropriate methods and materials for containment and cleanup. Appendix D requires Section 6(a) to cover personal precautions, protective equipment, and emergency procedures and Section 6(b) to describe methods and materials for containment and cleaning up (Appendix D to 1910.1200).

• Provide clear steps for spill response, recommended PPE for cleanup crews, and guidance on ventilating or isolating the area.
• Include disposal considerations or reference Section 13 when appropriate.

(See 1910.1200 App D.)

The SDS must state precautions for safe handling and conditions for safe storage including any incompatibilities. Appendix D Section 7 requires (a) precautions for safe handling and (b) conditions for safe storage, including incompatibilities (Appendix D to 1910.1200).

• Include temperature limits, ventilation requirements, segregation from incompatible chemicals, and special container requirements.
• If shelf-stability or specific storage atmospheres are required, note them clearly for safe use.

(See 1910.1200 App D.)

Section 10 must describe reactivity, chemical stability, possibility of hazardous reactions, conditions to avoid (e.g., static discharge, shock, vibration), incompatible materials, and hazardous decomposition products. Appendix D Section 10 explicitly lists (a) reactivity; (b) chemical stability; (c) possibility of hazardous reactions; (d) conditions to avoid; (e) incompatible materials; and (f) hazardous decomposition products (Appendix D to 1910.1200).

• Provide practical examples (temperatures, pressures, or substances) that could trigger instability or dangerous reactions.

(See 1910.1200 App D.)

The SDS must list a set of physical and chemical properties such as physical state, color, odor, melting/freezing point, boiling point, flammability, flash point, vapor pressure, pH, solubility, density, and others listed in Appendix D. Appendix D Section 9 enumerates required items including (a) physical state; (b) color; (c) odor (and odor threshold); (d) melting point/freezing point; (e) boiling point (or initial boiling point or boiling range); (f) flammability; (g) lower and upper explosion/flammability limits; (h) flash point; (i) auto‑ignition temperature; (j) decomposition temperature; (k) pH; (l) kinematic viscosity; (m) solubility; (n) partition coefficient n‑octanol/water; (o) vapor pressure; (p) density/relative density; (q) relative vapor density; and (r) particle characteristics (Appendix D to 1910.1200).

• Include the most relevant properties for safe handling (e.g., flash point, vapor pressure) and use the test method specified where applicable (see 1910.106(a)(5)).

(See 1910.1200 App D and 1910.106(a)(5) where boiling point test methods are noted.)

The SDS complements and expands on label information required under the Hazard Communication standard; both must be consistent and based on the same classification. The Hazard Communication rule 1910.1200 requires labels with signal words, pictograms, hazard statements and precautionary statements, and Appendix D requires the SDS to include the classification and the same hazard elements in Section 2 so that labels and the SDS align (1910.1200 and 1910.1200 App D).

• Ensure Section 2 of the SDS contains the same signal word, hazard statements, and pictograms shown on the label.
• Use the SDS to provide the detailed exposure and first‑aid information that labels cannot accommodate.

(See 1910.1200 and 1910.1200 App D.)

Yes. Appendix D makes Sections 1 through 11 and Section 16 mandatory on an SDS; Sections 12 through 15 are optional. Appendix D clearly states that an SDS shall include the information specified for sections 1–11 and 16, while sections 12–15 may be included but are not mandatory (Appendix D to 1910.1200).

• When choosing to include optional Sections 12–15, provide accurate transport, disposal, ecological, or regulatory information to help users comply with other laws.

(See 1910.1200 App D.)

If specific toxicological data for the chemical aren’t available, the preparer must indicate that alternative information was used and explain the method used to derive the toxicological information (for example, using data from a class of chemicals or structure–activity relationships). Appendix D Section 11(g) requires the preparer to state when alternative information is used and the method used to derive toxicological information (Appendix D to 1910.1200).

• Provide a clear description of the surrogate data source and rationale so downstream users understand limitations of the toxicity information.

(See 1910.1200 App D.)