As of 2017, the system has been enacted to a significant extent in most major countries around the world. This includes the European Union, which has implemented the United Nations’ GHS into EU law as the CLP Regulation, and OSHA standards. When creating an SDS it is important to be aware that the proper labeling and warnings are included for the country where the product will be sold—the place that regulates the product.
The 16 sections of an SDS are in a strict order. Sections 1 through 8 contain general information about the chemical, identification, hazards, composition, safe handling practices, and emergency control measures (e.g., firefighting). This information should be easily available to those who need to get the information quickly.
Sections 9 through 11 and 16 contain other technical and scientific information, such as physical and chemical properties, stability and reactivity information, toxicological information, exposure control information, and other information including the date of preparation or last revision.
Basic toxicological information is placed methodically in Section 11. While the specific format is not set, the acute data is a generally good place to start. Toxicological data such as the oral and dermal LD50s (the dose at which 50 percent of the specified animal exposed would be expected to die–this is a calculated formulaic number from a limited number of animals) as well as the inhalation LC50s (the concentration of a chemical in the air at which 50 percent of animals exposed would be expected to die). Basic information on skin, mucous membrane, respiratory and eye irritation as well as any repeated dose information also would be inserted in this section, as well as cancer listings from the International Agency for Research on Cancer, the Environmental Protection Agency, the National Toxicology Program, the American Conference of Governmental Industrial Hygienists, and the National Institute for Occupational Safety and Health, or OSHA. Any repeated dose studies that generate the no observed adverse effect level (NOAEL) should be briefly included here. Some companies insist on a full toxicological profile of the chemical in this section, while others put only minimal information.
There are other sections that depend on the information found in the toxicology section. For instance, Section 3, the Hazard Identification, applies the toxicological data to direct how the user must handle the product. This includes things other than toxicity (e.g., flammability, volatility, etc.). Any serious issues in handling the product must be pointed out here. Sometimes potential health effects also are detailed in this section. If the sheet is for global/EU use, then warning pictograms must go in this section (See Figure 1).
Section 4 is about first aid. There are stock phrases that appear in this section based upon the toxicological profile of the material. Section 5 covers firefighting measures and also can relate back to the toxicology section if the product has the potential for serious chemical reactions.
Section 12 is ecological information. This information is very important in the EU, which puts more emphasis on this than the U.S. historically has. EU regulators want to know the potential ecotoxicity to fish, daphnia, and algae, and if the product biodegrades or bio-accumulates, which can produce long-term harm to the environment.
The relevant regulatory information including exemptions, what agency takes precedence, rules to follow in the country that product is in, Toxic Substances Control Act (TSCA)–1976 Public Law 94-469) listing, etc., should be in Section 15.
Even for all its storied history and seemingly strict rules, the health and safety information found on current SDSs is still sometimes less than optimal. If no data is available for a particular product, then that can be stated and the SDS is in compliance with OSHA regulations. Interestingly, the regulations do not require that a preparer actually test a product/chemical. The preparer often makes their best-educated guesses or uses component toxicology data from the literature. To clarify some readings, such as skin or eye irritation, sometimes in vitro or other studies are run on the products, but this is the manufacturer’s prerogative.