CPL 02-02-079 , Appendix H

Guide for Reviewing Safety Data Sheet (SDS) Compliance

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NOTE: This guide has been developed for use as an optional aid during inspections. The information contained in this Appendix mirrors the information required in Appendix D of the standard , a mandatory appendix.

If a CSHO is reviewing an SDS for compliance, the following list of required elements may be helpful:

1. Section 1, Identification
   1. Product identifier that is on the label.
   2. Other means of identification.
   3. Recommended use and restrictions of use.
   4. Contact information for the responsible party (name, U.S. address, U.S. phone number).
   5. Emergency number – A number that reaches a knowledgeable person on the other end.

   There is no requirement for the emergency number to be staffed 24 hours per day if the SDS specifies the restrictions on the contact hours. The emergency contact number can be for a company contracted to provide information in the case of an emergency. The knowledgeable person must be able to answer questions and be understandable (e.g., speak English).

   Note: If the company name, address and phone number are located at the top of the page instead of in Section 1, this is a de minimis violation and a citation shall not be issued.



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2. Section 2, Hazard(s) identification
   1. Hazard Classification(s) – The Hazard Classification includes the hazard class and the category, e.g., Flammable Liquid, Category 1, unless that information is unknown for the chemical. This includes hazards classified under paragraph (d)(1)(i).
   2. Signal word(s), hazard statement(s), symbols (pictograms without the border) or a description of the symbol, precautionary statement(s) (not including hazards not otherwise classified and hazards identified and classified under paragraph (d)(1)(ii)).
   3. Hazards classified under paragraph (d)(1)(ii) .
   4. Description of any hazards not otherwise classified (HNOC) that have been identified during the classification process.
   5. Unknown acute toxicity percentage if the ingredient(s) with unknown acute toxicity is present at a concentration ≥ 1% and the mixture is not classified based on testing of the mixture as a whole.
3. Section 3, Composition/information on ingredients

   1. For substances:

      1. Chemical name.
      2. Common name and synonyms.
      3. Chemical Abstract Service (CAS) Registry number and other unique identifiers.
      4. If the chemical is a substance, impurities, and stabilizing additives (constituents) which are themselves classified and which contribute to the classification of the substance.

   2. For mixtures, in addition to the information required for substances, the SDS must include the chemical name, CAS number or other unique identifier, and concentration (exact percentage) or concentration ranges of all ingredients which are classified as health hazards in accordance with paragraph (d) and

      1. are present above their cut-off/concentration limits; or
      2. present a health risk below the cut-off/concentration limits.
      1. Note: When CAS number is not available or claimed as a trade secret, the preparer must indicate the source of the unique identifier. Concentration ranges may only be used where a trade secret is claimed in accordance with paragraph (i) , for batch-to-batch variability, and for a group of substantially similar mixtures.
      2. Where a trade secret is claimed in accordance with paragraph (i) of § 1910.1200, a statement that the specific chemical identity, and/or concentration (exact or range) of the composition has been withheld as a trade secret is required. When the concentration or concentration range is withheld as a trade secret, the prescribed concentration ranges used in §1910.1200(i)(1)(iv) – (vi) must be used.


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4. Section 4, First-aid measures
   1. Necessary first aid measures by route of exposure.
   2. The most important symptoms and when they occur (acute/delayed).
   3. Whether medical attention is needed immediately and any special treatment, if necessary.
5. Section 5, Fire-fighting measures
   1. Suitable (and unsuitable) extinguishing media.
   2. Any specific hazards caused by combustion of the material.
   3. Special PPE and precautions for fire-fighters.
6. Section 6, Accidental release measures
   1. Precautions, PPE, and emergency procedures required.
   2. Methods/materials for containment and cleanup.
7. Section 7, Handling and storage
   1. Precautions for safe handling.
   2. Safe storage conditions, including incompatibilities.
8. Section 8, Exposure controls/personal protection
   1. For all ingredients or constituents in Section 3, OSHA permissible exposure limit (PEL), American Conference of Governmental Industrial Hygienists (ACGIH) Threshold Limit Value (TLV)®, other exposure limit(s) or range(s) used or recommended by the SDS preparer (including ceiling and other short-term limits).
   2. Appropriate engineering controls.
   3. Protective measures (e.g., PPE).
9. Section 9, Physical and chemical properties
   1. Physical state
   2. Color
   3. Odor (includes odor threshold)
   4. Melting point/freezing point
   5. Boiling point (or initial boiling point or boiling range)
   6. Flammability
   7. Lower and upper explosion limit/flammability limit
   8. Flash point
   

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   9. Auto-ignition temperature
   10. Decomposition temperature
   11. pH
   12. Kinematic viscosity
   13. Solubility
   14. Partition coefficient n-octanol/water (log value)
   15. Vapor pressure (includes evaporation rate)
   16. Density and/or relative density
   17. Relative vapor density
   18. Particle characteristics
10. Section 10, Stability and reactivity
    1. Reactivity
    2. Chemical Stability
    3. Possibility of hazardous reactions including those associated with foreseeable emergencies
    4. Conditions to avoid (e.g., static discharge, shock, vibration)
    5. Incompatible materials
    6. Hazardous decomposition products
11. Section 11, Toxicological information
    1. Routes of exposure.
    2. Symptoms related to the physical, chemical and toxicological characteristics.
    3. Immediate, delayed, and chronic effects from short- and long-term exposure.
    4. Numerical estimates of toxicity (such as acute toxicity estimates).
    5. Interactive effects (information on interactions should be included if relevant and readily available)
    6. Whether a chemical is listed by NTP, IARC or OSHA as a carcinogen.
    7. When specific chemical data or information is not available, the preparer must indicate if alternative information is used and the method used to derive the information (e.g., where the preparer is using information from a class of chemicals rather than the exact chemical in question and using SAR to derive the toxicological information).
12. Section 12, Ecological information (Non-mandatory)

    The lack of information in these sections is not citable; however, this heading is required and its absence would be a de minimis violation, see note 1 to 1910.1200(g)(2) .

13. Section 13, Disposal considerations (Non-mandatory)

    The lack of information here is not citable, however this heading is required and its absence would be a de minimis violation, see note 1 to paragraph 1910.1200(g)(2) .

14. Section 14, Transport information (Non-mandatory)

    The lack of information here is not citable, however this heading is required and its absence would be a de minimis violation, see note 1 to paragraph 1910.1200(g)(2) .



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15. Section 15, Regulatory information (Non-mandatory)

    The lack of information here is not citable, however this heading is required and its absence would be a de minimis violation, see note 1 to paragraph 1910.1200(g)(2) .

16. Section 16, Other information, including date of preparation or last revision
    1. Date of preparation or last revision – This does not mean date of printing. The use of the statement “valid on the date of printing only” is inconsistent with the requirements of the HCS as the SDS is intended to be a reference document that reflects the most accurate and current information about a specific hazardous chemical that is available at the time the SDS is developed.
    2. If new information has become available, the SDSs must be updated within three months, see 1910.1200(g)(5).

If there is no relevant information for a section or subsection (e.g., flash point), the SDS must state that no applicable information is available (NA or none).

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The official, public domain, OSHA version of this document is available at https://www.osha.gov/sites/default/files/enforcement/directives/CPL-02-02-079_0.pdf.