SDS Review Checklist: 12 Common Safety Data Sheet Errors to Fix Before Publication

A Safety Data Sheet (SDS) can contain every expected heading and still include errors that affect hazard communication, workplace safety, or regulatory alignment. Before publication, reviewers should examine the hazard classification, product information, technical data, label elements, and consistency across the document—not only spelling and formatting.

This checklist focuses primarily on U.S. SDSs prepared under OSHA’s Hazard Communication Standard (HCS). Products sold in other markets may be subject to additional requirements.

Key Takeaway

Before publishing an SDS, confirm that the hazard classification is supported by current data, required information is complete, the SDS and shipped-container label are consistent, and the document reflects applicable regulatory requirements.

12 Common SDS Errors to Check Before Publication

1. Using Outdated Regulatory Requirements

Confirm which requirements apply to the product and intended market, as older templates may not reflect current classification, labeling, or jurisdiction-specific rules.

Under OSHA’s 2024 HCS update, manufacturers, importers, and distributors evaluating substances were required to comply by May 19, 2026, including applicable SDS and shipped-container label updates. For affected substances, employers have until November 20, 2026, to update alternative workplace labels, the written Hazard Communication program, and employee training as necessary when newly identified hazards apply. The corresponding deadline for mixtures is November 19, 2027.

Review the current OSHA Hazard Communication Standard to determine which requirements apply.

2. Applying an Incorrect Hazard Classification

An incorrect or unsupported classification can impact the entire SDS (not just Section 2). When an incorrect classification is assigned, it can result in additional sections (such as Sections 4–11) being populated with inaccurate parameters, requirements, and safety measures. This may lead to inappropriate controls being applied, potentially affecting compliance, risk assessments, and operational procedures.

Confirm that each classification is supported by relevant product, ingredient, test, or scientific data. Do not rely on an older SDS or a similar product without verifying that the formulation and available hazard information are comparable.

3. Using Inconsistent Product Identifiers

The product identifier (or Trade Name) in Section 1 should correspond with the identifier used on the shipped-container label.

Check product names, codes, synonyms, brand names, and intended uses. Inconsistent identifiers can make it difficult to connect the SDS with the correct product.

4. Providing Incomplete Responsible-Party Information

For a U.S. OSHA SDS, Section 1 should include the name, U.S. address, and U.S. telephone number of the manufacturer, importer, or other responsible party, along with an emergency phone number.

Verify that the information is current. Products sold outside the United States may require different supplier or emergency-contact information.

5. Creating Conflicts Between Section 2 and the Label

Section 2 and the shipped-container label should communicate consistent hazard information.

Compare the product identifier, signal word, pictograms, hazard statements, precautionary statements, and any applicable supplemental information.

This review is separate from an employer’s obligation to update alternative workplace labels. Employers should compare updated supplier information with their workplace-labeling system and make changes where necessary.

6. Mishandling Ingredient Information

Review chemical names, common names, identifiers, concentrations or concentration ranges, and applicable trade-secret statements in Section 3.

Ingredient disclosures should support the hazard classification and follow the requirements that apply to the product. Trade-secret concerns should not be used to omit information that must be provided.

7. Leaving Emergency Instructions Too Vague

Sections 4, 5, and 6 should provide practical information for foreseeable exposures, fires, and accidental releases.

Check exposure routes, symptoms, medical attention, extinguishing media, combustion hazards, protective equipment, spill precautions, and emergency procedures. Generic instructions may not reflect the product’s actual hazards.

8. Omitting Handling, Storage, or Incompatibility Information

Section 7 should describe safe handling and storage precautions. Section 10 should identify incompatible materials, conditions to avoid, hazardous reactions, and hazardous decomposition products.

Review these sections together so that storage instructions do not conflict with the stability and reactivity information.

9. Providing Incomplete Exposure-Control or PPE Guidance

Section 8 should include applicable occupational exposure limits, engineering controls, and personal protective equipment.

Review whether the recommendations address relevant eye, face, skin, body, and respiratory protection, as well as ventilation or other engineering controls.

10. Leaving Required Technical Information Blank

Review Sections 9, 10, and 11 for missing, outdated, or unsupported physical, chemical, stability, and toxicological information.

Under OSHA Appendix D, when no relevant information is available for a required subheading, the SDS should state that no applicable information is available rather than leaving an unexplained blank.

Do not use “not applicable” when “no data available” is the more accurate description.

11. Allowing Contradictions Between SDS Sections

An SDS should communicate a consistent hazard profile.

For example:

• Physical-property data should align with the applicable physical-hazard classification.
• Exposure routes should correspond with first-aid information.
• Storage precautions should reflect identified incompatibilities.
• Toxicological information should support the listed health hazards.

A cross-section review can identify problems that may not be obvious when sections are checked separately.

12. Skipping Revision Control and Final Quality Review

Section 16 should include the SDS preparation date or date of the last revision.

Before release, confirm the version, units, language, references, product and company information, label alignment, formatting, and approval history. The final reviewer should also confirm that the SDS applies to the current formulation and intended market.

Final Pre-Publication SDS Review Checklist

Before approval, confirm that:

• The product and intended jurisdictions are identified.
• The classification is supported by current information.
• Required headings and information are complete.
• The SDS and shipped-container label are consistent.
• Ingredient disclosures and trade-secret statements are appropriate.
• Emergency, storage, exposure-control, and PPE guidance reflects the product’s hazards.
• Missing information is explained and contradictions are resolved.
• The revision date and approval record are current.

For additional background, see CHEMTREC’s guide on how to create an SDS in the United States.

When Should an SDS Be Updated?

For U.S. OSHA SDSs, a fixed three- or five-year review cycle is not a federal requirement.

When a chemical manufacturer, importer, or employer preparing an SDS becomes newly aware of significant information about a chemical’s hazards or ways to protect against those hazards, the new information must be added to the SDS within three months.

Periodic portfolio reviews may still help identify formulation changes, new hazard information, outdated supplier details, regulatory changes, or documents that no longer match their intended markets. Other jurisdictions may have different update requirements.

How CHEMTREC Supports SDS Authoring, Access, and Distribution

CHEMTREC provides three distinct SDS Solutions services.

SDS Authoring: CHEMTREC’s SDS Authoring service supports SDS creation, updates, ongoing maintenance, and quality review for multiple jurisdictions and languages. The service is supported by Certified Safety Data Sheet Registered Professional specialists and established quality-review processes.

SDS Access:SDS Access provides secure, 24/7 web-based access to a searchable SDS library.

SDS Distribution:SDS Distribution supports electronic delivery of SDS documents to authorized distributors, contractors, or customers upon request.