SDS for a small manufacturer or importer

If you manufacture a chemical product in the US, OSHA requires you to prepare an SDS before shipping the product to any business customer. If you import a chemical product without an SDS, you — the importer — are responsible for preparing one before passing the product to anyone.

First-time manufacturers often underestimate what 'preparing' an SDS entails. It requires performing a GHS hazard classification on your product (not just copying from ingredient SDSs), filling in product-specific physical and chemical properties, and ensuring the document meets the 16-section OSHA HazCom format.

A practical approach for a first SDS: use a drafting tool like SDSDraft to generate the 16-section structure from your ingredient list, then work with a safety consultant to verify the classification and fill in the sections requiring measurement or professional judgment. This is less expensive than full-service SDS authoring and gives you a document you understand.

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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First SDS checklist for small manufacturers

  1. Gather all ingredient SDSs from your chemical suppliers. These are your primary data source.
  2. List all ingredients with CAS numbers, concentrations, and their GHS H-codes from supplier SDSs.
  3. Determine the product-level GHS classification from your ingredient list (SDSDraft does this as a starting draft).
  4. Measure or confirm physical properties: appearance, pH, flash point, boiling point, density.
  5. Identify the correct emergency phone number — a 24/7-staffed line. CHEMTREC is a common option.
  6. Determine transport classification — contact your freight carrier or a transport compliance consultant.
  7. Write Section 15 regulatory information — TSCA status, any applicable state requirements.
  8. Have a qualified safety professional review and sign off on the classification before first shipment.

Questions

I import a product from overseas. The supplier's SDS is in a different language. What do I do?

You must provide an English-language SDS that meets OSHA HazCom format to US customers. If the imported product has a foreign SDS, you need to either translate and reformat it or prepare a new GHS SDS based on the ingredient information from the supplier. As the importer, you are responsible for classification accuracy.

Can I use the supplier's SDS for my own product?

Only if you are reselling the product unchanged and in the same concentration, and the supplier's SDS covers your product. If you reformulate, blend, or dilute the product, you need your own SDS for the resulting mixture.

What if I'm unsure whether my product is 'hazardous'?

If you are uncertain, start with a draft SDS anyway — it is better to have one than not. Then consult a safety professional to determine whether your product meets GHS classification thresholds. Many small-maker products (water-based, low-concentration surfactants, plant oils) may not be classified hazardous under GHS, but this determination requires professional verification.

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