How to create a Safety Data Sheet for your product

If you manufacture or import a hazardous chemical product in the US, OSHA HazCom 2012 (29 CFR 1910.1200) requires you to provide a Safety Data Sheet (SDS) to anyone who handles that product in a workplace. This includes soap, cleaning products, cosmetics, candles, and any consumer product that contains ingredients with GHS hazard classifications.

An SDS must follow the GHS 16-section format. The sections cover identification, hazard classification, ingredient composition, first aid, fire-fighting, spill response, handling, exposure controls, physical properties, stability, toxicology, ecology, disposal, transport, regulatory information, and revision history.

You can pay a professional SDS authoring service $1,000–$1,500 per document, or start with a draft using a tool like SDSDraft and then have a safety professional verify it. Either way, the accuracy of the hazard classification is your responsibility as the manufacturer or importer.

SDSDraft generates a DRAFT safety data sheet from the information you enter. You are solely responsible for verifying the hazard classification and all content with a qualified person before use or distribution. SDSDraft is software, not professional safety, legal, or toxicological advice.

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The 16 sections every SDS must contain

  1. Section 1: Identification — product name, manufacturer, address, emergency phone.
  2. Section 2: Hazard identification — GHS classification, signal word, hazard and precautionary statements, pictograms.
  3. Section 3: Composition/ingredients — ingredient names, CAS numbers, concentrations, H-codes.
  4. Section 4: First-aid measures — by route of exposure (eye, skin, ingestion, inhalation).
  5. Section 5: Fire-fighting measures — suitable extinguishing media, hazardous combustion products.
  6. Section 6: Accidental release measures — spill containment and cleanup.
  7. Section 7: Handling and storage — safe handling procedures, storage conditions.
  8. Section 8: Exposure controls/PPE — OELs, engineering controls, protective equipment.
  9. Section 9: Physical and chemical properties — appearance, pH, flash point, density, etc.
  10. Section 10: Stability and reactivity — stability, incompatibilities, decomposition products.
  11. Section 11: Toxicological information — routes of exposure, LD50/LC50, chronic effects.
  12. Section 12: Ecological information — aquatic toxicity, persistence, bioaccumulation.
  13. Section 13: Disposal considerations — waste codes, disposal methods.
  14. Section 14: Transport information — UN number, packing group, DOT/IATA/IMDG classification.
  15. Section 15: Regulatory information — TSCA, SARA, Prop 65, REACH as applicable.
  16. Section 16: Other information — revision history, key to abbreviations, sources.

Questions

Who needs an SDS?

US manufacturers and importers of hazardous chemicals must prepare an SDS and make it available to downstream users (employers, distributors, retailers). Consumer products sold directly to the public have a partial exemption under HazCom, but products sold to businesses (including via wholesale) require an SDS. Verify with a regulatory professional for your specific situation.

Can I write my own SDS?

Yes, if you have the training to perform a proper GHS hazard classification. Most small manufacturers use an SDS authoring service, a safety consultant, or a drafting tool like SDSDraft as a starting point, then have a qualified person verify the classification.

How often do I need to update my SDS?

HazCom requires updating an SDS whenever significant new information becomes available about hazards or protective measures. At minimum, review your SDS annually and whenever you change your formulation or receive new information from ingredient suppliers.

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