Safety Data Sheet (SDS) Writing

Beginner Guide

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SDS authoring is a complex and time consuming process, which requires experience and qualification. As written in the “Holy Grail” of SDS regulations document, the Globally Harmonized System of Classification and Labelling of Chemicals (GHS), the SDS authors should be competent persons, who regularly attend refresher courses and training on the preparation of SDS, which in reality takes a lot of time and resources. At the end, it is usually cheaper and more productive to use the help of professional SDS writers. Thus, the cost of authoring service for a fully compliant SDS by productSDS Global SDS Authoring Center is very affordable with special lower rates for similar or multiple products.

Nonetheless, it is important for manufacturers/suppliers to ensure the contents of their products’ SDSs are compliant with corresponding regulations. Thus, it is a good practice to have at least some basic knowledge of SDS writing process even when using the services of outsourced SDS authoring companies.

SDS Authoring Software

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Most SDS authoring companies use special SDS authoring software, which should be regularly updated to reflect changes in target market regulations. The use of software definitely makes the SDS authoring process significantly more efficient. Some SDS authoring software is also readily available for purchase by any manufacturer/supplier for internal generation of SDS. There is some software available for free. However, even with the use of software, the SDS authoring process includes a lot of manual entries into the software, which requires professional knowledge and training.

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SDS Writing Layout

 

Most developed countries adopted standard GHS SDS format established by the United Nations. Such SDS consists of 16 sections. However, each country may have their own requirements on SDS format, chemical classifications and contents, including translation into official languages. Countries like Canada and USA also allow for certain SDS layout, which is acceptable in both countries, although their standard national formats have some differences.

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Although the requirements on SDS content may vary from country to country, the basic GHS introduced principles remain the same. Thus, after gaining enough experience in generation of SDS under one national regulation, it should be much easier to convert corresponding SDSs into formats of other target markets.
Herein we would like to provide instructions on compiling SDSs for USA market under (OSHA HCS 29 CFR 1910.1200(g) and GHS Rev 3). Subsequently, instructions on how to convert these SDSs to make them compliant with regulations in other countries and regions, such as Canada, Mexico, China, Japan, Europe, Russia etc., will be provided.

As previously discussed, SDS in USA (OSHA HCS 29 CFR 1910.1200(g)) must be written in English and should include the following sections in this particular order:

Section 1. Identification
Section 2. Hazard(s) identification
Section 3. Composition/information on ingredients
Section 4. First-aid measures
Section 5. Fire-fighting measures
Section 6. Accidental release measures
Section 7. Handling and storage
Section 8. Exposure controls/personal protection
Section 9. Physical and chemical properties
Section 10. Stability and reactivity
Section 11. Toxicological information
Section 12. Ecological information (not mandatory)
Section 13. Disposal considerations (not mandatory)
Section 14. Transport information (not mandatory)
Section 15. Regulatory information (not mandatory)
Section 16. Other information
 

Tips on writing SDS sections for USA market
(according to OSHA HCS 29 CFR 1910.1200(g) and GHS Rev 3)

Detailed information on the contents of each section can be found in the official OSHA HCS and GHS documents. The instructions are quite straight forward, but some of them may seem too general, so the following information will only provide practical tips on how to put together corresponding SDS sections. There is some flexibility in how you can arrange information in each section of SDS, but one way of doing it is shown below.

Section 1. Identification
 

[The following subsections could be used for this section]:

1.1    Product Identifier
Product name: [provide trade name]
Other names (optional): [provide other names, such as product codes, alternative names etc.]

1.2    Recommended use of the chemical and restrictions on use
[Describe recommended product use, for example countertop cleaner.
Optionally, describe restrictions on the use, for example not to mix with oxidizers]

1.3    Supplier's contact details
[Provide name, address, and telephone number of the manufacturer, importer, or other responsible party. The contact company does not necessary reside within USA]

1.4    Emergency phone number
[Provide emergency phone number. It is very common to open an account with emergency response service companies, such as CHEMTREC, which could provide 24/7 emergency phone number service]


Section 2. Hazard(s) identification
 

[The following subsections could be used for this section]:

2.1 Classification of the substance or mixture
[Provide summary hazard classification of the product based on hazard information provided in subsequent sections of SDS]

2.2    GHS label elements, including precautionary statements
[Based on the classification, provide appropriate signal word(s), hazard statement(s) and precautionary statement(s). Further information on such statements will be provided in subsequent sections. Pictograms (or hazard symbols) may be provided in this subsection as well. OSHA’s pictograms can be found here]

2.3 Other hazards which do not result in classification
[Optionally, provide other potential hazards, which were not mentioned in previous sub section. Otherwise, just write none known.]

Section 3. Composition/information on ingredients
 

[As written in OSHA requirements, you need to provide information on composition of your product here, which includes concentration of ingredients (by mass), their common chemical name, and CAS number]
 

CAS number    Chemical Name    Concentration
        

[For mixtures, you do not have to mention ingredients below certain cut-off health hazard concentrations (see subsequent sections). Also, many manufactures provide concentration ranges for different components and/or choose not to specifically identify certain components due to trade secret. In this case you must include the following phrase on SDS]:

The specific chemical identity and/or exact percentage (concentration) of composition has been withheld as a trade secret

Section 4. First-aid measures

[Actual first aid measures depend on the properties of the product (see subsequent sections). A good detailed practical guide on first-aid measures can be found here. The following subsections can be used in this section]:

4.1 Description of necessary first-aid measures
[You need to provide first aid measures for each possible route of exposure]:

After inhalation: [you can find instructions here]
After skin contact: [you can find instructions here and here]
After eye contact: [you can find instructions here]
After swallowing: [you can find instructions here]

4.2    Most important symptoms/effects, acute and delayed
[If available, provide typical symptoms after potential exposure to the product]

4.3 Recommendations for immediate medical care and special treatment needed
[If available, provide special instructions here]

Section 5. Fire-fighting measures

[The following subsections can be used here]:

5.1 Suitable extinguishing media
[Provide suitable media here, such as CO₂, extinguishing powder or water spray, alcohol resistant foam]

5.2 Special hazards arising from the substance or mixture
[Unless there are some other special hazards, provide chemical names of potential oxidation products, such as different oxides, which could arise from burning the product]

5.3 Recommendations on special protective equipment or precautions for firefighters
[Unless there are some special instructions or precautions, such as for explosives, you can write here, for example]:
Wear self-contained breathing apparatus and full protective gear to prevent contact with skin and eyes.

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To be continued...

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