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How do I tell if a Safety Data Sheet (SDS) is legal?

This guide will help you understand how to read, and assess the quality of a safety data sheet. Download this page as a pdf

Fundamentally the ultimate test of any SDS is:
“Does this document provide me with the information to take the necessary steps to protect people and environment?”

If you have doubts about the information in an SDS then we recommend that you contact your supplier.

The 16 sections of an SDS are detailed in the rest of this guide along with some key pointers to help you assess the quality of the information.

Section 1 – Identification of the Substance/Preparation and of the Company/Undertaking

• Name of product
• Intended use of product
• Contact details - a European address and telephone number
• E-mail address of the person responsible for the SDS 
• Emergency telephone number with hours of operation specified

Section 2 – Hazards Identification
This section should contain a clear description of the hazards presented to people and the environment. It should be consistent with Section 3 and Section 15.  For example, if in Section 3 you see that the product contains 90% of a substance that is classified as toxic by inhalation, you would expect an overall “Toxic” classification and this would be reflected in the regulatory information (the label) detailed in Section 15.

Section 3 – Composition/Information on Ingredients
Each hazardous substance (ingredient) present in the product will be listed here.  You should find details on:

• Chemical name
• EINECS or ELINCS number
• Concentration or concentration range
• Risk phrases associated with that ingredient

If the substances are listed in the Table 3.2 of part 3 of Annex VI of the CLP regulation (which replaces the HSE’s Approved Supply List), you should check the classifications match those given in this section. Check if the substances are listed in EH40.  Cross check the exposure limits given in Section 8.

Section 4 – First-Aid Measures
The actions that the first person at the scene of an incident could take.  Look out for:

• Advice following exposure through different routes (contact with skin and eyes, breathing in fumes or swallowing the substance)
• Check advice is consistent with Section 2 and Section 9
• Have you got suitable first aid equipment available in your workplace?

Section 5 – Fire-Fighting Measures
Information given should be consistent with Section 2 and Section 9.  Key information to look for:

• What can I use/not use to put out the fire?
• Hazardous combustion products (e.g. harmful fumes)
• Special advice for trained fire fighters.

Section 6 – Accidental Release Measures
This section should help you manage small and large product spills whilst protecting people and the environment. Again, this should be consistent with Section 2 and Section 9.

Section 7 – Handling and Storage
This gives information to help protect your staff.  This should be used to inform your COSHH risk assessment. 

• Details of how to handle the product safely (including use of engineering controls) and to minimise release to the environment
• Advice on where to store the product (e.g. refrigerated or heated storage).  You will also find information about compatibility with materials used in standard storage vessels.

Section 8 – Exposure Controls/Personal Protection
Provides detailed advice on how employees can minimise exposure to the product. If available, threshold limits should be given that should not be exceeded.  Engineering controls (e.g. use of ventilation systems) or Personal Protection Equipment (PPE) should be specified.

Key information:

• Exposure limits from EH40, published by the HSE
• All ingredients with an associated exposure limit should be included in Section 3
• Check that exposure limits match those in EH40
• Engineering controls – what are they and when to use them
• Personal Protective Equipment (PPE) - advice on protection from exposure to eyes, skin and inhalation

Section 9 – Physical and Chemical Properties

Make sure this relates to the product as supplied. As a minimum we would expect: colour, flash point, pH, density and water solubility.

In addition, REACH states that the following data should also be included, where relevant:  boiling point/range, flammability (solid, gas), explosive properties, oxidising properties, vapour pressure, fat solubility, partition coefficient (n-octanol/water), viscosity, vapour density and evaporation rate.

Section 10 – Stability and Reactivity

• Conditions to avoid
• Materials to avoid
• Hazardous decomposition products
• Possible stabilizers

Section 11 – Toxicological Information

• Acute toxicity (poisoning) by eating, breathing and skin absorption
• Corrosivity to the eyes, skin and respiratory tract
• Chronic toxicity (long term effects) e.g. sensitisation, carcinogenicity, mutagenicity and reproductive toxicity

Section 12 – Ecological Information

• The potential effects of release to air, land or water
• Ecotoxicity – in particular to fish, daphnia and aquatic   plants

Section 13 – Disposal Considerations

• Reference to Hazardous Waste Regulations
• Suitable disposal methods for product and packaging

Section 14 – Transport Information

• Classification for road, rail, sea and air
• Key information – UN Number, Proper Shipping Name, Hazard Class and Packing Group

Section 15 – Regulatory Information

• Should reflect information in Section 2
• Describes product label – symbols for hazard classification, risk and safety phrases

Section 16 – Other Information

List of the full wording of all risk phrases used throughout the SDS (including those for all ingredients identified in Section 3).

Glossary
ACOP - Approved Code of Practice – issued by HSE to help companies meet the requirements of legislation
ADR - Laws controlling transport of hazardous goods by road
CLP - Classification, Labelling and Packaging of chemicals regulations - replaces CHIP
CHIP - Chemicals (Hazard Information and Packaging for Supply) regulations - gradually being replaced by CLP
COSHH - Control of Substances Hazardous to Health regulations
EH40 - HSE publication providing guidance on safe chemical exposure limits
EINECS - European Inventory of Existing Chemical Substances
ELINCS - European List of New Chemical Substances
IATA / ICAO - Air transportation laws for chemicals
IMDG - International sea transportation laws for chemical products
REACH - Registration, Evaluation, Authorisation and Restriction of Chemicals regulation – sets out the requirements for safety data sheets
RID - Rail transportation laws