Short answer: an SDS has 16 sections, always in the same order
A safety data sheet (SDS) consists of 16 sections in a set order, as required by the Globally Harmonized System of Classification and Labelling of Chemicals (GHS). This format is used in the US, Canada, the EU, the UK, Mexico, and other regions around the world.
OSHA’s Hazard Communication Standard (HazCom) requires SDSs to be in English and to include all 16 section headings in the specified order. Sections 12 to 15 must be present, though OSHA does not regulate their content.
This addresses the most common question. For those preparing SDSs, it is also important to understand the specific requirements for each section, their relationships, and regional variations. This guide reviews all 16 sections from the manufacturer’s perspective. Each section covers:
- Required content, and the regulation it comes from
- Common errors when authoring
- Cross-checks against other sections of the SDS
- Regional differences, where the rules differ by region
The 16 sections at a glance
Tap a section to jump to it. OSHA enforces the content of every section except 12 to 15 (shown lighter), whose headings are still required.
Identity, hazards and composition
Who supplies the product, what its hazards are, and what is in it. Section 2 drives the label, so get these three right first.
Identification
- Required content
Provide the product identifier, supplier’s name, U.S. address and phone number, an emergency contact number, and recommended use and restrictions. The 2024 HazCom update specifies that the responsible party must be located in the United States.
- Common errors
Inconsistent product names across the SDS, label, and order system can make it difficult for customers to identify the correct document. Supplier details and emergency numbers may become outdated following organizational changes.
- Cross-checks
- §7§8
Ensure the product identifier matches the label exactly. Recommended uses should align with handling advice in Section 7 and controls in Section 8.
- Regional differences
- CASection 1 names the initial supplier, meaning the Canadian manufacturer or importer. The emergency number doesn’t have to be Canadian, but any limits on it (hours, languages) must be stated.
- EUSection 1 is split into four numbered subsections (1.1 to 1.4). Section 1.1 must say if the substance is a nanoform and list the Unique Formula Identifier (UFI) where one is required. Section 1.4 usually carries national poison centre numbers.
- UKThe supplier listed must be based in Great Britain.
Hazard(s) identification
- Required content
The classification, the label elements (pictograms, signal word, hazard and precautionary statements), and other hazards that don’t lead to classification. In the US that includes hazards not otherwise classified (HNOC).
- Common errors
Errors in Section 2 affect the entire label. Frequent issues include using outdated ingredient data for classification, omitting relevant ingredients in mixture calculations, and copying precautionary statements from similar products.
- Cross-checks
- §3§9§11§8§14
Review all related sections. Section 3 should list ingredients responsible for each classification. Section 9 must support physical hazards, and Section 11 must support health hazards. Section 8 PPE should correspond to these hazards. If Section 14 differs, make sure you can explain why.
- Regional differences
- EUClassification follows CLP, which now includes hazard classes the US doesn’t have, such as endocrine disruptors and PBT/vPvB. Section 2.3 must flag endocrine-disrupting properties.
- CAWHMIS includes classes not in HazCom, such as biohazardous infectious materials.
We cover Section 2 in detail, across HazCom, WHMIS and CLP, in Section 2 of the SDS.
Composition/information on ingredients
- Required content
For substances: the chemical name, common names and synonyms, CAS number and impurities that contribute to the classification. For mixtures: each hazardous ingredient with its CAS number and concentration, as set out in Appendix D of HazCom.
- Common errors
Section 3 often becomes outdated first when raw materials change. Another frequent issue involves trade secrets. Under the 2024 update, withheld concentrations must be reported using OSHA’s prescribed ranges, such as 1 to 5% or 10 to 30%, rather than arbitrary ranges.
- Cross-checks
- §2§8
Section 2. Every ingredient that drives a classification should be here. Every ingredient here above its cut-off should show up in the classification. Exposure limits in Section 8 should line up with the ingredients listed.
- Regional differences
- CAThe prescribed concentration ranges for confidential business information match OSHA’s. Canada and the US aligned them on purpose.
- EUList REACH registration numbers, plus specific concentration limits, M-factors and acute toxicity estimates where they exist. Nanoforms need their particle characteristics.
- MXIngredients above the NOM-018 cut-offs need a chemical identity and a concentration or range. A confidential ingredient can be withheld, but the SDS must say it is confidential.
What workers read in a hurry
Sections 4 to 8 are practical and often referenced during spills, fires, or exposures, sometimes by individuals unfamiliar with the product. Ensure all content is specific to this product. Avoid using generic text from other SDSs, as it is easily identified and may be inaccurate.
First-aid measures
- Required content
First-aid steps by route of exposure (inhalation, skin, eyes, ingestion), the most important symptoms and effects (acute and delayed), and when immediate medical attention or special treatment is needed.
- Common errors
Using generic statements such as “get medical attention if symptoms persist” for corrosive products or skin sensitizers. Omitting delayed effects. Recommending induction of vomiting, which is rarely appropriate.
Fire-fighting measures
- Required content
Suitable and unsuitable extinguishing media, specific hazards from the chemical (such as hazardous combustion products), and special protective equipment and precautions for firefighters.
- Common errors
Indicating water as suitable for water-reactive products. Omitting specific combustion products, such as hydrogen chloride or nitrogen oxides, which are critical for firefighter safety.
Accidental release measures
- Required content
Personal precautions, protective equipment and emergency procedures, plus methods and materials for containment and cleanup.
- Common errors
Specifying spill response PPE that is less protective than routine handling PPE in Section 8. Recommending absorbents incompatible with the product, such as sawdust for oxidizers.
Handling and storage
- Required content
Precautions for safe handling and conditions for safe storage, including any incompatibilities.
- Common errors
Using vague storage instructions, such as “store in a cool place,” for products with specific temperature limits. Omitting incompatibilities listed in Section 10.
- Cross-checks
- §10§9
Section 10 conditions and materials to avoid, and the physical properties in Section 9, such as flash point and self-heating.
- Regional differences
- EUSection 7.3 covers specific end uses and points to exposure scenarios where a chemical safety report exists.
Exposure controls/personal protection
- Required content
OSHA permissible exposure limits (PELs), ACGIH threshold limit values (TLVs) and any other exposure limit the preparer recommends. Also engineering controls and personal protective equipment, such as eye, skin, hand and respiratory protection.
- Common errors
Copied text is most prevalent in this section. Frequent issues include PPE recommendations that do not match hazards in Section 2, unspecified glove materials for “chemical-resistant gloves,” and exposure limits for ingredients not listed in Section 3.
- Cross-checks
- §2§3§6
Section 2 hazards, Section 3 ingredients and the PPE in Section 6. Our guide to SDS Section 8 exposure limits goes deeper.
- Regional differences
- CAList limits that apply where the product is sold. Provinces set their own occupational exposure limits.
- EU · UKInclude the national limits, such as EU indicative limit values, and in the UK the Workplace Exposure Limits (WELs) in EH40. Derived no-effect levels (DNELs) and predicted no-effect concentrations (PNECs) from a REACH registration go here too.
- MXUse the occupational exposure limits set in NOM-010-STPS-2014.
Where the data lives
Sections 9 to 11 contain the data supporting the classification. Some values are based on internal testing, while others are sourced from literature or suppliers’ SDSs for raw materials. Data gaps often appear here first, so review these sections against Section 2 as a priority.
Physical and chemical properties
- Required content
The 2024 HazCom update reorganized this list to match the GHS. It now includes physical state and color (replacing “appearance”), odor (which absorbs odor threshold), melting and boiling points, flammability, explosive limits, flash point, auto-ignition and decomposition temperatures, pH, viscosity, solubility, partition coefficient, vapor pressure (which absorbs evaporation rate), density and relative vapor density. It also adds particle characteristics for solids.
- Common errors
Leaving fields blank without explanation. If a property does not apply or data is unavailable, state this clearly. HazCom requires the SDS to indicate when no relevant information is found. Other frequent issues include missing units and presenting properties from a single ingredient’s SDS as if they apply to the entire mixture.
- Cross-checks
- §2§5§7§10
Section 2. A missing flash point makes a flammable liquid classification impossible to check. pH supports, but doesn’t decide, a corrosion classification. Section 9 should also fit Sections 5, 7 and 10.
- Regional differences
- EURegulation (EU) 2020/878 brought the same reorganization in earlier. It also added Section 9.2.1 for information on physical hazard classes and 9.2.2 for other safety characteristics.
- USAfter OSHA’s four-month extension, the manufacturer deadline for substances was May 19, 2026. Mixtures must meet the 2024 format by November 19, 2027.
Stability and reactivity
- Required content
Reactivity, chemical stability, the possibility of hazardous reactions, conditions to avoid (heat, static, shock), incompatible materials and hazardous decomposition products.
- Common errors
Providing only “stable under normal conditions” without further detail. Listing incompatible materials that do not match Section 7, and decomposition products that do not align with Section 5.
Toxicological information
- Required content
Likely routes of exposure, symptoms tied to the physical, chemical and toxicological characteristics, delayed, immediate and chronic effects, numerical measures of toxicity (such as LD50 and LC50 values and acute toxicity estimates), and whether the chemical is listed as a carcinogen by NTP, IARC or OSHA.
- Common errors
Toxicology that does not align with Section 2 health hazards, often due to sections being written at different times. Another issue is listing a carcinogen in Section 3 but omitting it from Section 11. The 2024 update adds: if you use read-across data to classify a health hazard, Section 11 must state this and identify the chemical or process used.
- Regional differences
- EUSection 11.1 covers the CLP hazard classes. Section 11.2 covers other hazards, including endocrine-disrupting properties.
- CAWHMIS asks for the same core information, in English and French.
Required headings, content OSHA doesn’t enforce
Under HazCom, the content of Sections 12 to 15 is not mandatory, because ecology, disposal, transport and other regulations fall outside OSHA’s jurisdiction. To stay consistent with the GHS, the headings must still appear, in order. Canada works the same way under WHMIS.
These sections are not optional in practice. In the EU and UK, all four are required. US customers, carriers, and agencies such as the EPA and DOT also expect this information. Complete these sections accordingly.
Ecological information
- Recommended content
Aquatic and terrestrial toxicity, persistence and degradability, bioaccumulative potential, mobility in soil and other adverse effects.
- Common errors
“No data available” on a product classified as hazardous to the aquatic environment in Section 2. Ecotoxicity data that doesn’t support the environmental classification.
- Regional differences
- EUSection 12.5 covers the PBT and vPvB assessment, and Section 12.6 now covers endocrine-disrupting properties.
Disposal considerations
- Recommended content
Safe handling of waste, disposal methods and contaminated packaging.
- Common errors
Providing only “Dispose of in accordance with local regulations” without further detail. While not incorrect, this is unhelpful. Specify likely waste characteristics where possible, such as whether the product may be classified as ignitable hazardous waste under RCRA.
Transport information
- Recommended content
HazCom lists seven items: UN number, UN proper shipping name, transport hazard class(es), packing group, environmental hazards (such as marine pollutant: yes or no), transport in bulk, and special precautions for users.
- Common errors
Assuming transport classification matches the GHS classification in Section 2. Often, it does not. Transport regulations use different criteria and thresholds, so a product may be regulated for shipping but not under HazCom, or vice versa. Another error is providing information for only one mode when the product ships by road, sea, and air.
- Cross-checks
- §9§12
Section 9 (flash point and boiling point drive Class 3 packing groups) and Section 12 (marine pollutant). We walk through why the two classifications differ in GHS vs DOT classification.
- Regional differences
- EUSection 14 transport information is compulsory for every relevant mode, under ADR, RID, ADN, IMDG and IATA.
Regulatory information
- Recommended content
Safety, health and environmental regulations specific to the product.
- Common errors
Including irrelevant or outdated laws. For US products, the most important lists are typically TSCA inventory status, SARA Title III (Sections 302, 311/312, and 313), California Proposition 65, and state right-to-know lists.
- Cross-checks
- §3
Section 3. Every listed ingredient should be checked against each regulatory list you cite.
- Regional differences
- EUSection 15.1 covers EU and national rules, such as REACH authorizations and restrictions and the Seveso Directive. Section 15.2 says whether a chemical safety assessment was done.
- UKCite GB regulations (UK REACH, GB CLP), not the EU versions.
- CAMany suppliers add Domestic Substances List (DSL) status, though WHMIS doesn’t require it.
Other information
- Required content
The date the SDS was prepared or last revised. Anything else the author wants to add goes here too, such as a revision log, abbreviations and data sources.
- Common errors
Omitting the revision date, or updating the date with each reprint even if no changes were made. A clear and accurate date allows customers, auditors, and your team to identify the current version.
- Regional differences
- CAThe date of the latest revision is required.
- EUSection 16 should show what changed from the previous version.
The 16 sections by region
All five regions use the same 16 headings in the same order. The differences are in language, how much of Sections 12 to 15 is required, and how fast an update is due.
| US | Canada | EU | UK | Mexico | |
|---|---|---|---|---|---|
| Rule | OSHA HazCom (29 CFR 1910.1200) | WHMIS (Hazardous Products Regulations) | REACH Annex II, as amended by (EU) 2020/878, and CLP | UK REACH Annex II and GB CLP | NOM-018-STPS-2015 |
| Language | English | English and French | Official language(s) of each member state where sold | English | Spanish |
| Sections 12 to 15 content | Not enforced; headings required | Not required; headings required | Required | Required | Headings required; content follows the competent authority |
| Numbered subsections | No | No | Yes (1.1, 1.2 and so on) | Yes | Lettered sections with listed items |
| Supplier in Section 1 | US-based responsible party | Canadian manufacturer, importer or distributor | EU supplier | GB-based supplier | Manufacturer or supplier, plus emergency phone |
| Update trigger | Significant new information, within 3 months | Significant new data, within 90 days | New information, “without delay” | New information, “without delay” | New information that changes classification, or new chronic health data; no fixed deadline |
| Trade secret concentrations | Prescribed ranges | Prescribed ranges (same as US) | ECHA confidentiality rules and alternative names | Similar to EU | Allowed if the SDS states it is confidential business information |
In Mexico, NOM-018 requires the SDS (HDS, or hoja de datos de seguridad) to be in Spanish and include all 16 sections. We cover it in Mexico NOM-018-STPS-2015. For a side-by-side look at the three biggest markets, see US, EU and Canada SDS requirements.
Keeping all 16 sections current
Writing the SDS is not a one-time task. Under HazCom, any significant new information about a chemical’s hazards or protective measures must be added to the SDS within three months. If the chemical is not currently produced or imported, updates must be made before it re-enters the workplace. Canada allows 90 days, while the EU requires updates without delay.
In practice, it is important to identify which SDSs are impacted when a raw material, test result, or regulation changes. A single supplier SDS update can affect Sections 2, 3, 8, 9, 11, and 14 across multiple products. Older MSDS files that do not follow the 16-section format are another common gap. Refer to MSDS vs SDS for key differences.
Free download
The SDS Cross-Check Checklist puts every check from this guide into a four-page PDF, organized by section, with regional add-ons for Canada, the EU, the UK and Mexico.
How Valenc helps
Valenc generates all 16 sections. AI extracts data from supplier SDSs and reviews the completed SDS. A rules engine classifies the product, and sections are built from a curated phrase library.
SDS authoring is available for the US, Canada, Mexico, the EU, the UK, and the UN, in over 25 languages. Field extraction achieves over 98% accuracy with per-field confidence scores, allowing you to identify values that may require review. Your formulations are never used to train models. See SDS authoring for details and GHS classification for information on the rules engine.
FAQ
How many sections are in an SDS?
Sixteen. Under HazCom, the SDS must be in English and carry the 16 headings in the listed order. Canada, the EU, the UK and Mexico use the same 16 sections.
Do the sections have to be in order?
Yes. The 16 headings must appear in the order the standard lists them.
Which SDS sections does OSHA not enforce?
Sections 12 to 15: ecological information, disposal, transport and regulatory information. The headings must still appear. In the EU and UK, their content is required.
What changed in Section 9 with the 2024 HazCom update?
“Appearance” became physical state and color, odor threshold merged into odor, evaporation rate merged into vapor pressure, and particle characteristics were added.
When do manufacturers have to comply with the 2024 HazCom update?
The manufacturer deadline for substances was May 19, 2026. For mixtures, it is November 19, 2027.
Which section of the SDS lists PPE?
Section 8, exposure controls and personal protection.
How often does an SDS need to be updated?
There is no fixed cycle for suppliers. In the US, significant new information must be added within three months. In Canada, it’s 90 days.
Is a Canadian SDS different from a US SDS?
Same 16 sections. A Canadian SDS must be in English and French and name a Canadian supplier, and WHMIS has some hazard classes that HazCom doesn’t.
Valenc will index up to 100 of your SDSs at no cost. This offer is available to any chemical manufacturer or distributor through December 31, 2026. Files are submitted through a secure portal, and you will receive the index within three business days of receipt. To view a draft of all 16 sections, request a demo.
