OSHA SDS Authoring Guidance: Everything You Need to Know

In the United States, the Occupational Safety and Health Administration (OSHA) sets clear rules on how SDSs must be written, formatted, and maintained. Following OSHA’s SDS authoring guidance ensures that workers, employers, and emergency responders have the right information to handle hazardous chemicals safely.

This article explains OSHA’s requirements for SDS authoring, the structure of an SDS, common mistakes to avoid, and how manufacturers can stay compliant.

OSHA’s Role in SDS Authoring

OSHA’s Hazard Communication Standard sets the rules for how chemical hazards must be classified and communicated. It aligns with the Globally Harmonized System (GHS) to bring consistency across industries and countries.

Under OSHA’s SDS authoring guidance, manufacturers, importers, and distributors must prepare SDSs for every hazardous chemical they produce or supply. These documents must give complete, accurate information on hazards, handling, and emergency response.

Most companies now use SDS authoring software to organize this process. These tools help maintain consistency with OSHA’s formatting and GHS classifications, reducing the risk of missing required data.

The Required Format: 16 Standard Sections

OSHA requires all SDSs to follow a 16-section format based on GHS. Each section must appear in the same order to make information easy to find.

1. Identification – Product name, manufacturer details, recommended uses, and restrictions.
2. Hazard Identification – Classification, signal word, hazard statements, symbols, and precautionary statements.
3. Composition/Information on Ingredients – Details on substances, mixtures, and concentration ranges.
4. First-Aid Measures – Steps for exposure through skin, eyes, inhalation, or ingestion.
5. Fire-Fighting Measures – Suitable extinguishing media and special precautions.
6. Accidental Release Measures – Cleanup procedures and protective measures.
7. Handling and Storage – Safe practices and storage requirements.
8. Exposure Controls/Personal Protection – Exposure limits, engineering controls, and PPE.
9. Physical and Chemical Properties – Data such as appearance, odor, pH, flash point, and solubility.
10. Stability and Reactivity – Conditions to avoid hazardous decomposition products.
11. Toxicological Information – Health effects and exposure routes.
12. Ecological, Disposal, Transport, and Regulatory Information – Section 12-15 are required by GHS but not enforced by OSHA. However, most companies include them for completeness.
13. Other Information – Preparation date, revision number, and version history.

Following this structure is central to proper SDS authoring. Missing or reordering sections can make the SDS noncompliant.

Hazard Classification and Labeling

Before writing an SDS, each chemical must be properly classified. OSHA requires manufacturers to evaluate all available data on the chemical’s health and physical hazards.

The classification determines the signal word (such as “Danger” or “Warning”), the hazard statements (like “Causes skin irritation”), and the pictograms that must appear on both the label and the SDS.

SDS authoring systems help apply the right classification codes automatically, using built-in regulatory databases that align with OSHA’s latest GHS revision. This reduces errors and keeps labeling consistent between the SDS and the physical product.

Accuracy and Data Validation

OSHA expects all data included in an SDS to be accurate, current, and verifiable. Manufacturers must use reliable sources, such as supplier SDSs, scientific literature, and laboratory test data. When multiple data sources exist, the most credible and relevant information must be used.

A robust review process helps maintain accuracy. Each SDS should undergo technical review by qualified personnel before release. This includes checking chemical names, CAS numbers, exposure limits, and physical data for consistency across sections.

Language and Readability

OSHA emphasizes clear, straightforward language for SDS authoring. Technical terms should be used only where necessary and defined when possible. The goal is to ensure that workers can understand the content without confusion.

SDSs must be written in English for use in the United States. However, manufacturers who export chemicals often need to prepare localized versions in other languages, following each region’s GHS implementation.

Recordkeeping and Version Control

Manufacturers must keep the latest version of every SDS readily available to employees. When a chemical’s formulation or hazard information changes, the SDS must be updated.

Revision dates and version numbers should be listed in Section 16. Old versions should be archived for reference, as OSHA may request them during inspections.

Proper version control prevents outdated or conflicting SDSs from circulating in the workplace or supply chain.

Common Mistakes in SDS Authoring

Even experienced manufacturers can make errors. The most frequent issues include:

• Using outdated hazard classifications or phrases
• Leaving required sections incomplete
• Copying supplier data without verification
• Failing to update after regulatory changes
• Inconsistent information between the label and SDS

Regular audits and cross-checks are key parts of OSHA’s SDS authoring guidance and help prevent these issues.

Training and Competence

OSHA’s guidance also highlights the importance of training. Employees who prepare SDSs must understand hazard classification, GHS rules, and chemical terminology. Ongoing training ensures they stay informed about changes to regulations or chemical data.

Employers must also train workers who use chemicals to read and understand SDSs as part of the overall hazard communication program.

Staying Compliant with OSHA

Compliance is not a one-time task. Manufacturers must regularly review their SDSs to ensure they reflect current data and regulatory changes. Establishing an internal schedule for periodic reviews is considered best practice.

Online SDS authoring systems make this process easier by providing review schedules and update reminders. They help manufacturers stay aligned with evolving OSHA regulations and GHS revisions.

Conclusion

OSHA SDS authoring guidance provides a clear framework for how Safety Data Sheets must be created, structured, and maintained. Compliance ensures accurate communication of hazards and supports a safe workplace.

Manufacturers who follow these guidelines maintain both safety and regulatory confidence. An accurate, well-structured SDS is not only a legal requirement but also a sign of professional responsibility in chemical management.