How to check a safety data sheet: SDS review checklist in…

Contents

When should an SDS be checked?
Three layers: format, consistency, content
How to check an SDS in 12 steps
What to do when you find a problem
What an automatic SDS check can and cannot do
Frequently asked questions
Sources

In short: checking a safety data sheet (SDS) works in three layers: first the format (16 sections, mandatory subsections, date, language), then consistency between sections (do sections 2, 3, 9 and 14 agree with each other), and finally the content (are the classification and the values right). The first two layers can be done methodically and partly automatically; the third is expert work. This guide walks through that order, step by step, for an SDS you have received or are about to publish.

When should an SDS be checked?

There are two situations, and the goal is the same in both: the document must be complete and internally consistent enough for the user to take the right measures at the workplace.

Before publishing (the author): in the EU the supplier is responsible for the SDS (REACH Article 31); in Türkiye it must be prepared by a Chemical Assessment Expert (KDU) (KKDİK Article 27). The final read-through comes after the classification and the text editing, and it is repeated at every formulation change and revision.
On receipt (the user): the SDS feeds the risk assessment and decisions on storage, personal protective equipment and waste. An assessment built on an incomplete or contradictory sheet stays incomplete. A short intake check on every incoming SDS, especially from a new supplier or for a new revision, is therefore a good habit.

Three layers: format, consistency, content

Layer	Question asked	Who can do it?
1. Format	Are the 16 sections and mandatory subsections present, are empty sections justified, are the date and language right?	Anyone; largely checkable automatically.
2. Consistency	Does the classification in section 2 agree with the ingredients in section 3, the physical data in section 9 and the transport information in section 14?	A technical reader; partly checkable automatically.
3. Content	Are the classification, categories, limit values and measures right for this product?	An expert; needs test data and the formulation.

The order matters: debating the content of a sheet whose format is incomplete wastes time, and a consistency error is often the first symptom of a content error.

How to check an SDS in 12 steps

16 sections in order: REACH Annex II (and KKDİK Annex 2) require 16 sections with fixed headings and order.
Subsections: are subsections such as 1.1-1.4, 2.1-2.3, 3.1/3.2 and 14.1-14.7 in place? If information is not available, the subsection stays and the reason is given.
Date and version: is the revision date clear, and what changed? The law sets no fixed renewal period; it requires an update when new information becomes available (REACH Article 31(9)).
Language and legal references: the SDS must be in the official language of the country where it is placed on the market (REACH Article 31(5)). References to repealed acts and R-phrases suggest an outdated sheet.
Product identifier: the name in 1.1 must be the same as on the label (CLP Article 18).
Contact and emergency: supplier and e-mail address in 1.3, an emergency telephone number reachable in the target country in 1.4.
Ingredients: are the CAS/EC numbers in section 3 valid, do the lower bounds of the ranges add up to more than 100, does each classified ingredient carry its hazard information?
2 ↔ 3: do the classification and share of the ingredients support the mixture classification in section 2?
2.1 ↔ 2.2: do the label elements (signal word, pictograms, H and P statements) follow from the classification?
2 ↔ 9 ↔ 14: if there is a flammable liquid class, is the flash point in section 9; if there is a hazard relevant for transport, is it reflected in section 14?
8 and 15: is an ingredient with an occupational exposure limit listed in section 8, and a Candidate List substance (SVHC) mentioned in section 15?
11 and 12: for every hazard in section 2, is there information in the toxicological and ecological sections or a reason why data are missing?

For a printable, section-by-section version of these steps, use the SDS checklist; for details of the consistency steps (8-12), see SDS consistency between sections. The errors authors make most often are covered separately: common SDS mistakes.

What to do when you find a problem

As the author: fix the finding at its source. A format gap is fixed in the template; a consistency error is fixed first in the classification, then in the sections derived from it (2.2, 14, 15). Fixing one section and leaving the others creates a new inconsistency.
As the user: send the finding to the supplier in writing and ask for a corrected version. Do not edit the sheet yourself: the supplier is responsible for its content. In the EU, the downstream user's duty to inform the supplier of new hazard information, or when the risk management measures offered seem inappropriate, is set out in REACH Article 34.

What an automatic SDS check can and cannot do

Layers 1 and 2 can be expressed as rules, so software can scan them. The Chemoris SDS checker for an SDS compliance check focuses on these two layers: it reads a PDF with a text layer or a .docx file, runs 22 checks covering structure, identification, composition and 2 ↔ 3 ↔ 14 consistency, and tells you in which section each finding sits and what type it is.

Its limits matter: the tool does not give the correct value. It says "the acute toxicity category in section 2 looks inconsistent with section 3"; it does not state the right category. It cannot read scanned (image) PDFs, and it does not judge the meaning of sections 4-7, 10 and 13, only whether they are present. Finding no clear issue does not mean the sheet is compliant. The tool is not a substitute for expert assessment; layer 3 is always the expert's job.

Frequently asked questions

Who should check an SDS?

The final check before publishing belongs to the person who prepared it (in Türkiye, the KDU). The intake check of a supplier's SDS can be done at the format and consistency level by the safety officer, purchasing or quality; any doubt about the content goes back to the supplier.

Does an SDS expire?

No, the law sets no fixed period. The sheet is updated without delay when new information on hazards or risk management measures becomes available. A sheet that has not been revised for a long time is still worth reviewing for outdated legal references.

If an automatic check finds no issue, is the SDS compliant?

No. An automatic check only speaks about the rules it checks; it does not confirm that the classification and values are right. That confirmation needs expert assessment.

Can I correct an error in my supplier's SDS myself?

Rather than editing the supplier's sheet, send the finding in writing and ask for a corrected version. The supplier who provides the sheet is responsible for its content.

Sources

Regulation (EC) No 1907/2006 (REACH), Articles 31 and 34, Annex II (as amended by Regulation (EU) 2020/878).
Regulation (EC) No 1272/2008 (CLP), Articles 17-28.
KKDİK Regulation (23/06/2017, Official Gazette No 30105), Article 27 and Annex 2; amendment: No 32408 (23/12/2023).

Related codes

H and P statements related to this topic; each is explained in the glossary with its full wording, thresholds and label use.

How to check a safety data sheet: SDS review checklist in 12 steps