Section 8 may appear straightforward, but preparing it calls for careful work. A U.S. SDS must link the ingredients listed in Section 3 to the relevant exposure limits, engineering controls, and personal protection information.
OSHA Appendix D requires Section 8 to address three areas: occupational exposure limits, appropriate engineering controls, and individual protection measures such as PPE. The regulation also specifies that for each ingredient or constituent listed in Section 3, the SDS must provide the OSHA PEL, the ACGIH TLV, and any other limit used or recommended by the preparer, where available.
The working rule
Develop Section 8 based on the Section 3 ingredient list and the product’s actual exposure scenario. Do not reuse previous exposure-control tables without verifying both elements.
What OSHA requires in SDS Section 8
Appendix D breaks Section 8 into three required content areas:
For all ingredients or constituents listed in Section 3: the OSHA permissible exposure limit (PEL), the ACGIH Threshold Limit Value (TLV), and any other exposure limit or range used or recommended by the SDS preparer, where available.
Appropriate engineering controls.
Individual protection measures, such as personal protective equipment.
The first requirement is often underestimated. Section 8 tables should not rely on generic lists of limits; they must be verified against the specific composition disclosed in Section 3.
Start with Section 3, not with the exposure-limit table
The most reliable approach is to use the finalized Section 3 ingredient list and review each entry for applicable occupational exposure limits. This ensures that every ingredient in Section 3 has its Section 8 exposure-limit field reviewed.
Not every ingredient will have a PEL or TLV. If no relevant limit exists, this should be stated explicitly. Appendix D requires the SDS to clearly indicate when no applicable information is available for a required subheading.
PEL and TLV are not the same thing
An OSHA PEL and an ACGIH TLV may both appear in Section 8, but they are not interchangeable and should be presented as distinct values.
| Item | What it is | How to present it |
|---|---|---|
| OSHA PEL | A regulatory occupational exposure limit under OSHA requirements. | Label it clearly as the OSHA PEL and include the value, units, and applicable basis. |
| ACGIH TLV | A health-based guideline published by ACGIH; ACGIH states that TLVs are guidelines, not regulatory standards. | Identify it as the ACGIH TLV and do not present it as an OSHA limit. |
| Other OEL | Another exposure limit or range used or recommended by the SDS preparer. | Name the source so the reader knows which limit is being applied. |
Retain the time basis and units
A numeric value alone is insufficient. Occupational exposure limits may be expressed as an 8-hour time-weighted average, a short-term exposure limit, a ceiling, or another defined form. Units may include ppm, mg/m³, fibers per cubic centimeter, or other appropriate measures.
If an authoring system imports only the numeric value and omits the units, averaging period, notation, or source, Section 8 may appear complete but will be unusable. The review must retain sufficient context for readers to understand each value.
Engineering controls should match the exposure scenario
Section 8(b) requires appropriate engineering controls. The term “appropriate” is important. Control recommendations should reflect the product and the likely exposure scenarios, rather than defaulting to generic ventilation language.
Depending on the product and task, controls may include local exhaust ventilation for vapors, mists, dusts, or fumes; process enclosure or isolation; general ventilation where appropriate; or closed transfer and other measures to reduce worker exposure.
The SDS does not replace a site-specific industrial hygiene assessment. A product used in a closed system may present a different exposure profile than when it is sprayed, heated, poured by hand, or processed in a way that generates dust.
PPE should follow the hazard and route of exposure
Section 8(c) addresses individual protection measures, including eye and face protection, gloves and protective clothing, and respiratory protection where required.
“Wear suitable PPE” is not a sufficient recommendation. Guidance should address the specific hazard and exposure route: splash protection for credible eye contact risks, glove material appropriate to the chemical and task, protective clothing for skin exposure, and respiratory protection where engineering controls are inadequate or required by other standards.
A practical Section 8 review
Before publishing a U.S. SDS, run a short reconciliation check:
- Does every ingredient or constituent listed in Section 3 have its Section 8 exposure-limit field reviewed?
- Where an OSHA PEL is available, is the correct value shown with its units and basis?
- Where an ACGIH TLV is available, is it identified as a TLV rather than presented as an OSHA limit?
- If another occupational exposure limit is used or recommended, is the source identified?
- Where no relevant limit is available, does the SDS clearly say that no applicable information is available?
- Do the engineering controls match the foreseeable exposure scenario?
- Do the PPE recommendations match the hazards and routes of exposure?
Section 8 should be an output, not a copied record
A recurring problem in SDS maintenance is treating the last published document as the source of truth. That is how old limits, generic ventilation language, and stale PPE recommendations get carried forward.
A stronger workflow starts from structured product data: composition, classification, exposure information, and jurisdictional requirements. Section 8 is then authored from the approved record and reviewed against Section 3 before publication.
Valenc follows that same sequence across GHS classification and SDS authoring: source data and classification first, then the downstream SDS output. Section 8 should also line up with the hazards shown in Section 2, and our guide to SDS Section 2 covers how that section works across HazCom, WHMIS and CLP.
