To author an SDS, follow four steps: gather your product and ingredient data, classify the hazards, write the 16 sections OSHA requires, and check the finished SDS against your labels. Done this way, the Safety Data Sheet meets OSHA’s Hazard Communication Standard (HazCom, 29 CFR 1910.1200).
Chemical manufacturers and importers must obtain or develop an SDS for each hazardous chemical they produce or import, under paragraph (g)(1) of the standard. This guide covers the US format in OSHA’s Appendix D, which is aligned with GHS; EU CLP/REACH and Canada’s WHMIS have their own rules.
Authoring a Safety Data Sheet is more than paperwork. It is how you communicate hazards and keep customers, workers, and responders safe.
Key takeaways
- An OSHA-compliant SDS uses 16 sections in a fixed order; Sections 12–15 may be included but are not mandatory.
- Collect each ingredient’s name, CAS number and concentration, plus supporting test data, before you start drafting.
- Classify hazards from your own test data first, then bridging principles, then the ingredients themselves.
- Before release, check that the SDS and the shipped-container label match on hazard classes, signal word and hazard statements.
- SDS authoring software such as ExactSDS classifies hazards from CAS numbers and fills all 16 sections; your team still reviews every SDS.
What must a compliant SDS include?
To author an SDS that is compliant in the US, you must follow OSHA’s HazCom Standard. The standard requires all SDSs to be in a 16-section format. Sections 12–15 may be included but are not mandatory, according to OSHA’s Appendix D; the other 12 sections are required.
What you need before you start
Have these ready before you open a template:
- The full formulation. Every ingredient with its exact percentage or allowed range.
- A CAS number for each ingredient; where none exists, note the source of the unique identifier you use.
- The supplier SDS for every raw material.
- Any test data you hold, such as physical and chemical properties or toxicology studies.
- The markets you sell into (US only, or also Canada or the EU), because each needs its own SDS format.
- The name, US address and US phone number of the responsible party, plus an emergency phone number.
Step 1: Define the product and gather source data
To start creating your SDS, the first step is to gather the product information you will place into specific SDS sections.
This includes product identifier, intended use, situations where it should not be used, company contact information, and an emergency number.
This should consist of each ingredient’s name, CAS No., typical concentration, any allowed range. The source for each value must also be included.
For the other sections physical or chemical data, toxicology summaries, and exposure limits need to be collected.
Confirm applicable OSHA PELs for Section 8. If you include other limits for context, label them as informational.
Once these worksheet inputs are ready, you can start classifying hazards with confidence.
Step 2: Classify hazards before starting the SDS draft
Classifying hazards is the most important part of writing an SDS. It is mainly stated in Section 2 and details involving hazards are written in other sections throughout the SDS.
If you have scientifically valid test data for your product, use it to determine the correct hazard classes and categories.
If your product doesn’t have direct test data, use Bridging Principles. This means applying reliable safety information from a similar product.
When neither test data nor bridging applies, classify the product based on its ingredients.
Classifying a mixture by hand? In ExactSDS, SDS Manager’s SDS Authoring Software, you enter each ingredient’s CAS number and choose the regulation. The software works out the hazard classification and drafts the precautionary statements, and you review and approve the result.
Start a free ExactSDS trial (no credit card required) →
Step 3: Create the SDS, section by section
Draft the document in OSHA’s required 16-section structure. Make sure your template reflects the current HazCom so terms and sub-headings stay consistent.
Quick reference: the 16 SDS sections
| Section & Heading | What to include | Authoring pointers |
|---|---|---|
| 1. Identification | Product identifier; recommended use; restrictions; responsible party contact; emergency number | Use the same product name/ID as on the label and in your system. |
| 2. Hazard(s) identification | Final hazard classes/categories; label elements: pictograms, signal word, hazard and precautionary statements | Cross-check with the shipped-container label; add the unknown acute toxicity line when required. |
| 3. Composition / information on ingredients | Hazardous ingredients with CAS and exact concentration or an allowed range; note any trade-secret claim | Use the prescribed concentration ranges to hide trade secrets; store exact concentration information internally. |
| 4. First-aid measures | Route-specific first aid; most important symptoms/effects; notes to physician | Keep instructions direct, and easy to follow during an emergency. |
| 5. Fire-fighting measures | Suitable media; hazards from combustion; protective equipment | State what to use to put out a fire and any special hazards to expect. |
| 6. Accidental release measures | Personal precautions; PPE; containment and cleanup | Separate action plans for small vs. large spills if they differ. |
| 7. Handling and storage | Safe handling; storage conditions; incompatibilities | Give clear storage temps/conditions and note what to keep away from. |
| 8. Exposure controls / personal protection | OSHA PELs; engineering/administrative controls; PPE | Mark any non-OSHA limits as informational. |
| 9. Physical and chemical properties | Appearance, odor, pH, flash point, vapor pressure, density, solubility, and other listed properties | Make sure the property list matches the current HazCom. |
| 10. Stability and reactivity | Reactivity; stability; hazardous reactions; conditions/materials to avoid; decomposition products | Ensure data accuracy since information from section 7 depends on it. |
| 11. Toxicological information | Likely exposure routes; symptoms; numerical measures such as ATE; major effects | Match statements to your classification notes, referring to the data used. |
| 12. Ecological information | Environmental fate and effects (if provided) | Not enforced by OSHA; often included for completeness. |
| 13. Disposal considerations | Waste handling and disposal guidance (if provided) | Give simple disposal advice that matches local rules and company policy. |
| 14. Transport information | UN number; proper shipping name; class; packing group (if provided) | Match any transport-relevant label elements. |
| 15. Regulatory information | Safety, health, and environmental regulations for the product | Avoid empty headings; state when no data are available. |
| 16. Other information | Revision date; description of changes; references | Keep a change-log so users can see what is new. |
*Sections 12–15 are not mandatory under OSHA’s HazCom.
With the draft complete, a quick check will confirm that the SDS and the shipped-container label match on hazard classes, the signal word, and required statements.
Step 4: Quality-check and align with labels
Before finalizing the SDS, it is important to cross-check labels, chemical properties from tests, legal exposure limits and other relevant information. This ensures that there is no conflicting information and saves later edits.
After this final check, the document is ready. If your product list changes often, consider online authoring tools to keep documents consistent with less manual work.
Common SDS authoring mistakes to avoid
- The SDS and the shipped-container label disagree on hazard classes, the signal word or hazard statements.
- A subheading is left blank. Appendix D requires the SDS to state clearly when no applicable information is available.
- Non-OSHA exposure limits appear in Section 8 without being marked as informational.
- An old template is used, so headings or listed properties no longer match the current HazCom.
- Section 16 has no date of preparation or last revision, so readers cannot tell which version they hold.
For the full set of rules behind each section, see our SDS authoring requirements guide.
When to use SDS authoring software, and what ExactSDS does
Creating an SDS by hand can be tedious and time-consuming, especially when doing it for multiple products.
When you manage many products or frequent updates, SDS Authoring software helps cut repeat work and keeps output consistent. For example, tools that offer classification help, version history and approvals, and label generation that mirrors Section 2.
In ExactSDS, the work follows the same order as the steps above:
- Enter each ingredient by CAS number and choose the regulation.
- ExactSDS works out the hazard classification and generates the hazard and precautionary statements.
- It fills in all 16 sections for you to review and edit.
- Create the SDS in 39+ languages when you sell into other markets.
- Track revisions and create a new version when a formula changes.
ExactSDS is software your team uses: you stay the author and approve every SDS. SDS Manager does not write SDSs for you. If you are comparing tools, see the best SDS authoring software compared.
These tools save time on formatting and version control so you can focus on clear, accurate content.
Author an Accurate SDS in Four Steps
Accurate SDS information helps prevent workplace accidents by giving people straightforward hazard statements, matching label details, and dependable first-aid and spill guidance.
To put this into practice, focus on four steps:
- Gather the right inputs
- Classify hazards using OSHA criteria
- Write to the required sections
- Confirm that the SDS, secondary container label, and transport label match on hazard classes, the signal word, and hazard statements.
When formulas change often, using a trusted authoring tool keeps every version current and consistent, which reduces mistakes and supports safer work practices.
FAQs
Who is allowed to author an SDS?
Any qualified person the manufacturer, importer, or distributor designates is allowed to author an SDS, because OSHA does not require a license or certification. That person should understand hazard classification and the 16 required sections, which is why many organizations train an internal “competent person” for the role.
Do I need Sections 12–15?
Yes, you need Sections 12–15 on the SDS, because OSHA requires all 16 section headings for consistency with GHS. However, OSHA does not enforce the content of these sections, since ecology, disposal, transport, and regulatory information fall under other agencies.
How often should an SDS be updated?
An SDS should be updated within three months of learning significant new information about a chemical’s hazards or how to protect against them. Update the label at the same time so it stays consistent with Section 2.
Can I reuse text across similar products?
Yes, you can reuse text across similar products, as long as it reflects each mixture’s actual hazards and properties. Keep records that support each product’s classification, in case a customer or inspector asks how it was determined.
What helps first-time authors most?
What helps first-time authors most is a clear template and a clean ingredient list with concentration ranges. A final check that the label matches Section 2 also catches the most common errors before publishing.