Outsourced SDS authoring services are best for teams with few SDSs, one-time projects, or limited regulatory expertise. SDS authoring software is ideal for teams managing many products, frequent reformulations, multiple regions, or those needing control over data and timelines. Many organizations use both. Regardless of the approach, the manufacturer, importer, or supplier remains responsible for SDS compliance under the laws cited below.
Valenc is a software platform and does not provide SDS authoring services directly. It partners with third-party authoring providers. This guide is intended to support your decision-making, not to promote a particular solution. Outsourcing remains a valid and, for some companies, the preferred option.
SDS authoring services and software: what the two models are
Outsourced authoring services require you to provide formulation data, product details, and any test data. An external team classifies the product, prepares the SDS in the required formats and languages, and returns it to you. Some providers also manage updates following regulatory or formulation changes. Service scope can range from full program management to support for overflow or single market launches.
With authoring software, your team enters or imports product data. The software applies classification and phrase logic to draft the SDS. Your team then reviews, edits, and approves the document, maintaining full control over the process and timeline.
A hybrid approach uses software for the core portfolio while outsourcing specific tasks. Further details are provided below.
Who is legally responsible for the SDS?
Begin with legal responsibility, as it influences your evaluation of each option. The laws below assign SDS duties to the manufacturer, importer, or supplier, not to a specific author or vendor. The cited texts do not address outsourcing. Please consult your regulatory professional and primary sources for confirmation.
United States (OSHA HCS, 29 CFR 1910.1200). Paragraph (g)(1) says chemical manufacturers and importers "shall obtain or develop a safety data sheet for each hazardous chemical they produce or import." Paragraph (g)(2) says the chemical manufacturer or importer "shall ensure that the safety data sheet is in English ... and includes at least the following section numbers and headings," which are the 16 sections. Paragraph (g)(5) says "the chemical manufacturer, importer or employer preparing the safety data sheet shall ensure that the information provided accurately reflects the scientific evidence used in making the hazard classification." Classification is assigned to manufacturers and importers under (d)(1). Under (g)(6)(i), manufacturers and importers must provide an SDS with the initial shipment and with the first shipment after an update, and distributors pass SDSs along under (g)(7). (eCFR)
If you ship only within the US, that paragraph is the one that applies. The rest of this section matters if you also sell into Canada, the EU or Great Britain.
Canada (Hazardous Products Act and Hazardous Products Regulations). Under HPA section 13(1)(a), no supplier shall sell a hazardous product intended for a workplace in Canada unless the supplier "has in their possession a safety data sheet" that meets the regulations. Section 14(a) sets the matching duty on import. Section 14.2 bars a supplier from selling or importing when the SDS is "false, misleading or likely to create an erroneous impression" about the information the SDS is required to contain. (HPA) The Regulations require SDS information in both official languages (section 6.2). (HPR)
European Union (REACH, Regulation (EC) No 1907/2006). Article 31(1) says "the supplier of a substance or a mixture shall provide the recipient ... with a safety data sheet compiled in accordance with Annex II" where the substance or mixture meets the CLP criteria for classification as hazardous, or in the other cases listed. Article 3(32) defines a supplier as "any manufacturer, importer, downstream user or distributor placing on the market a substance, on its own or in a mixture, or a mixture." Annex II, Part A, point 0.2.3 also says the SDS "shall be prepared by a competent person" and that suppliers "shall ensure that such competent persons have received appropriate training, including refresher training." (EUR-Lex, consolidated text) Great Britain has its own version of Article 31 under UK REACH, which requires the SDS to be supplied in English. (legislation.gov.uk, Art. 31(5))
In summary, while a service provider can prepare the SDS, your company, as the supplier, must have an in-house individual capable of reviewing, questioning, and approving the document. This responsibility applies to all models.
When SDS authoring services make sense
Outsourced services are typically preferable when:
You manage a small number of SDSs. For a limited product range, investing in a new system may not be justified.
The work is one-time or seasonal. Projects such as a single market entry, portfolio clean-up, or MSDS-to-SDS conversion are better suited to services.
You lack in-house regulatory expertise. If your team cannot assess classifications, outsourcing to qualified professionals is advisable.
Occasional but significant volume spikes occur. Regulatory changes may require simultaneous updates to many SDSs, and external support can help manage these periods.
You prefer not to manage a system. This eliminates the need for implementation, training, and ongoing administration.
When to choose SDS authoring software
SDS authoring software is typically preferable when:
You manage a large product portfolio. The greater the number of SDSs, the more manual work is repeated, making automation beneficial.
You frequently reformulate products. Each formula change can impact classification, Section 3, Section 9, transport data, and all language versions. A record-based system allows you to update data once and track all affected areas.
You sell in multiple regions. Each region has unique formats and regulations. A single product record that generates regional variants helps maintain consistency and reduces manual editing.
You require control over the process. You determine when SDSs are revised and published, and can track approvals.
You have a qualified reviewer. While software drafts the SDS, a knowledgeable individual must review and approve it.
Hybrid models
A hybrid approach is common and practical. Typical scenarios include:
Software for the steady portfolio, outside help for overflow during a regulatory change.
Software in-house, an outside specialist for a new region your team has not authored for before.
An outside team for the first pass on a legacy library, then software to maintain it.
Services for products with unusual hazards, software for routine mixtures.
The primary risk in a hybrid model is data fragmentation. Establish where the master data resides and ensure both internal and external teams use it. This is a key consideration for any SDS management system.
Decision table
| Factor | Services tend to fit | Software tends to fit |
|---|---|---|
| Number of SDSs | Few | Many |
| Frequency of change | Rare | Frequent reformulation or regulatory updates |
| Regions and languages | US only, or one or two stable markets | Several, growing |
| In-house expertise | Little or none | At least one qualified reviewer |
| Control over timing | Can plan around a provider's queue | Need to revise and publish on your own schedule |
| Formulation access | Comfortable sharing under agreement | Want data kept inside your own account |
| Audit trail | Ask whether it is available | Look for one built into the workflow |
| Setup effort | Scoping and data handoff | Data load, review and learning the tool |
| Best for | Projects, gaps, overflow | Ongoing programs |
Use the decision table as an initial guide. If your needs are divided, consider hybrid solutions.
Hidden costs, in effort, time and risk
Both models involve hidden work. Consider the following factors before making a decision.
Services
Data handoff effort. Someone must compile compositions, test data, and usage information for each product, and respond to follow-up inquiries.
Review time. You must review the returned SDS. Poor initial drafts can result in additional revision cycles.
Queue time. Turnaround times depend on the provider's workload and the scope of your request.
Change requests. Each reformulation requires a new request. Frequent changes lead to repeated handoffs.
Limited internal knowledge. Your team gains less insight into product classification decisions.
Consistency risk. Without established standards, different authors may use varying language across products or regions.
Software
Setup effort. Existing SDSs and product data must be imported and verified.
Learning curve. Your team must learn the software and its review process.
Ownership. Assign a responsible individual to manage the program and monitor regulatory changes.
Fit risk. Some tools require users to make classification and phrase choices, which can reintroduce consistency risks.
Exit risk. Confirm how you can export your data, in which formats, and under what conditions.
Turnaround and change control
Legal requirements set specific timelines for manufacturers, importers, or suppliers. Ensure you have clear agreements with any provider regarding how new hazard information is communicated to the responsible individual.
US. Under HCS (g)(5), when "the chemical manufacturer, importer or employer preparing the safety data sheet becomes newly aware of any significant information regarding the hazards of a chemical, or ways to protect against the hazards, this new information shall be added to the safety data sheet within three months." Labels have a separate six-month rule in (f)(11). For the HCS 2024 dates, see our HCS 2024 checklist.
Canada. HPR section 5.12 defines "significant new data". A sale or import made within 90 days after significant new data became available is exempt from putting that data on the SDS, if the buyer also gets an SDS with all other available information plus a document giving the required changes and the date the data became available (5.12(2)-(3)). A 180-day equivalent applies to labels (5.12(4)-(5)). Read the section for the exact conditions.
EU. REACH Article 31(9) says suppliers "shall update the safety data sheet without delay" when new information on hazards or risk management becomes available, when an authorisation is granted or refused, or when a restriction is imposed. The new version is identified as "Revision: (date)" and goes to recipients supplied in the previous 12 months.
When evaluating providers or tools, consider the following questions:
How does a new hazard finding reach the person who updates the SDS, and how quickly?
What is the turnaround for a revision, not just for a new SDS?
Who approves the final version, and is that recorded?
Is the revision date visible on the SDS? HCS (g)(2)(xvi) requires Section 16 to include the date of preparation or last revision.
Can you see the earlier version and what changed?
When a regulation changes, who works out which of your products are affected?
Who owns the formulation data?
Your composition data is highly sensitive. Regardless of your chosen approach, consider the following questions:
Is there a written confidentiality agreement, and who at the provider can see the data?
Where is the data stored, and what happens to it when the engagement ends?
Is your data ever used to train AI models?
Can you export your product data and finished SDSs, in a usable format, when you want to?
If the provider or tool changes, what do you keep?
Valenc's position, from its own site: compositions, documents and everything else you load are never used to train AI models, and you can export your data at any time with no fees. A REST API connects to ERP or PLM systems.
Valenc’s role in SDS authoring
Valenc is a software platform and does not provide SDS authoring services. For teams seeking external authoring, Valenc collaborates with third-party partners.
As software, Valenc reads supplier SDS PDFs with AI agents and shows every extracted field beside the source PDF with a confidence score. It enriches the data from a database of about 55,000 chemicals. A deterministic rules engine, not a language model, classifies the product. It then drafts all 16 SDS sections with SDS authoring software for the regions you choose: the US, Canada, Mexico, the EU, Great Britain, and the UN GHS module, with more regions being added. Phrases come from a curated library in 25+ languages, so translations stay consistent.
Your team reviews and approves. A review agent flags items that need a person's decision. Nothing publishes until a person approves it, and the audit trail runs from the source PDF to the published SDS. The rule behind each classification is shown. After publication, monitoring agents watch OSHA, EPA, REACH and CLP lists and flag affected SDSs in your library.
This model aligns with the "software" scenario described above: it is suitable for organizations with many products, frequent changes, multiple regions, and a need for control. A qualified reviewer is still required. Valenc drafts the SDS; your team approves it.
If you currently use an external authoring firm, you can still leverage Valenc. Import completed SDSs as PDFs, review the extracted data alongside the source documents, and determine later which tasks to transition in-house.
How to decide in five steps
Quantify your SDSs. How many do you maintain, and how many typically change each year?
List regions and languages. Include those you anticipate adding within the next two years.
Identify your reviewer. If no one can approve classifications, consider starting with services or a hybrid model.
Address data considerations. Evaluate confidentiality, training use, and data export options.
Test with your own products. Submit sample SDSs to any tool under consideration and formulation data to service providers, then evaluate the results. Refer to our guide on comparing SDS authoring software for evaluation criteria.
Frequently asked questions
Is outsourced SDS authoring worth it for a small company?
Yes, it can be worthwhile. For companies with few products and no regulatory specialist, outsourcing eliminates the need for software setup and training. Ensure you have an in-house reviewer to approve each SDS.
Who is responsible if an outsourced SDS is wrong?
The laws referenced above assign SDS responsibility to the manufacturer, importer, or supplier, not to a contractor. Consult your regulatory professional for guidance specific to your situation.
How often must an SDS be updated?
Under OSHA's HCS, updates are required within three months of becoming aware of significant new hazard information (paragraph (g)(5)). REACH Article 31(9) requires updates without delay. Canada's HPR section 5.12 provides a 90-day exemption under certain conditions. Confirm specific requirements for each market.
Can I use software and a service together?
Yes. Many organizations manage routine SDSs with software and use external authors for overflow, new markets, or specialized products. Ensure you establish where the master data is maintained.
Does software eliminate the need for regulatory expertise?
No. While software drafts SDSs and applies rules consistently, a qualified individual must still review and approve each document. In the EU and Great Britain, REACH Annex II requires that a competent person prepares the SDS.
Test it on your own SDSs
Valenc offers a walkthrough using your own supplier SDSs, allowing you to observe extraction, classification, and a review-ready draft for familiar products. Request a demo to learn more.
Chemical manufacturers can also access free SDS indexing for up to 100 SDSs per company, available through December 31, 2026.