The 16 sections of a safety data sheet explained

The 16 sections at a glance

The heading names above follow the OSHA list in 29 CFR 1910.1200(g)(2); the REACH Annex II headings are worded almost identically. The rules on who must supply an SDS and in which language differ by market: see SDS requirements in the EU, UK and US compared.

Sections 1 to 3: identity, hazards, composition

Section 1 identifies the product and the supplier and gives an emergency telephone number. Under REACH Annex II the subsection on the emergency number must clearly state when availability is limited, for example to office hours. A number that only reaches a sales office after 17:00 is the most common finding here. In the EU, if the mixture has a UFI and it is shown on the SDS, it belongs in subsection 1.1 (Regulation (EU) 2020/878).

Section 2 gives the classification and the label elements: pictograms, signal word, hazard and precautionary statements. The label elements must follow from the classification; a pictogram with no matching hazard class, or an H statement with no category behind it, is an immediate red flag. The pictogram rules are summarised in the 9 hazard pictograms, and the statement codes in how to read H and P codes. Subsection 2.3 lists other hazards that do not lead to classification, such as PBT/vPvB properties or, in the EU since 2020/878, endocrine disrupting properties.

Section 3 lists hazardous ingredients with their identifiers and concentrations or ranges. Reviewers check that every hazard in Section 2 can be traced back to an ingredient here. In the EU, specific concentration limits, M-factors and acute toxicity estimates must be shown for listed components where available (REACH Annex II as amended by 2020/878). Too-wide concentration ranges are another frequent problem, because they make the classification impossible to verify.

Sections 4 to 7: emergency and handling

Section 4 should describe first aid by route of exposure and the most important symptoms. A sheet for a corrosive product that says "rinse with water if irritation occurs" undersells the hazard. Advice for the doctor (antidotes, specific treatment) belongs here when it exists.

Section 5 names suitable and unsuitable extinguishing media and hazardous combustion products. Water jets on flammable liquids or on water-reactive solids are classic errors.

Section 6 covers personal precautions, environmental precautions and clean-up. It should point to Section 8 for PPE and Section 13 for disposal rather than repeat or contradict them.

Section 7 gives handling and storage conditions, including incompatible materials. These must match Section 10. A storage temperature in Section 7 that differs from the stability conditions in Section 10 confuses warehouse staff and auditors alike.

Sections 8 to 10: exposure, properties, reactivity

Section 8 is the section most often wrong for export. Occupational exposure limits are national: an EU indicative value, a German AGW, a UK WEL and a US OSHA PEL can all exist for the same substance. A sheet for a given market should list the limits that apply there. Glove advice should name a material and, where known, a thickness and breakthrough time; "suitable gloves" is not enough.

Section 9 lists physical and chemical properties. The flash point must be consistent with the flammable liquid category in Section 2, and pH with any corrosion classification. A blank cell is not acceptable under REACH Annex II, which states that a safety data sheet shall not contain blank subsections; write "not available" or "not applicable" with a reason.

Section 10 covers reactivity, stability, conditions to avoid, incompatible materials and decomposition products.

Sections 11 to 13: toxicology, ecology, disposal

Section 11 should go through the health hazard classes one by one and say, for each, whether the classification criteria are met and on what data. Copying an ingredient's LD50 without saying how the mixture was classified is a frequent weakness. For mixtures classified with the additivity formula, the resulting ATE is helpful here; see CLP mixture classification.

Section 12 covers aquatic toxicity, persistence, bioaccumulation and mobility. Its data must support the environmental classification in Section 2. In the US, OSHA requires the section but states that it will not enforce its content; in Europe it is fully mandatory.

Section 13 gives waste treatment methods. "Dispose of according to local regulations" alone adds nothing; mention the waste route and any packaging disposal advice.

Sections 14 to 16: transport, regulation, other

Section 14 gives the UN number, proper shipping name, transport hazard class, packing group and environmental hazard flag under the modal rules (ADR, IMDG, IATA, or US DOT). Transport classification is not a copy of the CLP classification; the criteria differ. Our guide on Section 14 and ADR explains the fields.

Section 15 lists safety, health and environmental regulations specific to the product, such as authorisation or restriction status in the EU. It is the most market-specific section; a sheet shipped to a new country almost always needs a new Section 15.

Section 16 holds the revision information, a key to abbreviations and the full text of H statements referenced in Section 3. REACH Annex II requires revised sheets to show what changed; many suppliers bump the revision date without saying where.

A five-point check before release

1. Does every hazard in Section 2 trace back to Section 3 and to the data in Sections 9, 11 or 12?
2. Do Sections 7 and 10 agree on storage conditions and incompatibilities?
3. Are Section 8 limits and Section 15 laws those of the market where the product is supplied?
4. Is Section 14 based on transport criteria for this product, not copied?
5. Is the revision date in Section 16, with changes indicated, and is the emergency number in Section 1 reachable as described?

A printable tick-off version of this check for all 16 sections: SDS checklist (16 sections).

Frequently asked questions

Is the section order the same in the EU and the US?

Yes. Both REACH Annex II and 29 CFR 1910.1200(g)(2) prescribe the same 16 sections in the same order, both based on the UN GHS.

Can a subsection be left empty if no data exist?

Not in the EU or GB: Annex II states that the SDS shall not contain blank subsections. State that data are not available or that the item is not applicable, and why.

How long should an SDS be?

There is no fixed length. REACH Annex II says the length should be commensurate with the hazard of the substance or mixture and the information available.

This checklist is general guidance; it is not legal advice and does not replace review by a competent person.

Sources

• REACH Annex II as amended by Commission Regulation (EU) 2020/878 — CELEX:32020R0878.
• UK REACH Annex II (GB text) — legislation.gov.uk.
• 29 CFR 1910.1200(g)(2) and Appendix D — osha.gov.
• CLP, Regulation (EC) No 1272/2008, Annex I — CELEX:02008R1272.