Hazard communication
Is your Safety Data Sheet still valid?
An out-of-date SDS can understate a hazard. The classic example is a chemical that has since been reclassified as a carcinogen.
An SDS is only as good as the information it was written with. As toxicology improves and regulations change, suppliers reclassify chemicals and revise their SDSs. A site still using a ten-year-old sheet may be giving workers the wrong PPE, the wrong exposure limits or the wrong storage advice.
Keeping SDSs up to date is the supplier's job. Using the current one is the site's job.
When an SDS must be updated
| Reason | Example |
|---|---|
| New hazard information | A carcinogenic or reproductive effect is found in new studies |
| Change in classification | A substance moves from Carcinogenicity Category 2 to Category 1B |
| New exposure limits | An occupational exposure limit is lowered, so ventilation or PPE must change |
| Change in formulation | The supplier changes an ingredient or its concentration |
| Legal changes | New national rules, such as the Hazardous Chemicals Regulations, 2024 |
How to check an SDS before buying or accepting a delivery
- Format: it has all 16 GHS sections. An old MSDS layout is a warning sign.
- Identity: the product name, grade and supplier match the container exactly.
- Revision date: it is in Section 16 or the header. Ask the supplier to confirm it is the latest version.
- Classification: Section 2 gives GHS classes and categories, not just a description of hazards.
- Composition: Section 3 lists hazardous ingredients with CAS numbers and concentration ranges.
- Exposure controls: Section 8 names specific glove and respirator types, not just "wear suitable PPE".
- Carcinogen check: for any Category 1A, 1B or 2 carcinogen, Section 8 gives exposure limits and engineering controls.
- Language: it is in English and readable by the people who will use it.
Who is responsible? The supplier must provide an accurate, current SDS. The employer must keep it available at the point of use and act on it. That includes revising risk assessments, PPE and storage when an SDS changes.
What to do
- Add an SDS check to procurement, so no chemical is ordered or accepted without a current, compliant SDS.
- Review the SDS library at least once a year (best practice is every quarter), and request updates from suppliers.
- When an SDS changes, record what changed and update the related risk assessments and toolbox talks.
- Remove superseded SDSs from the point of use, so only the current version is available.
How INRC can help
Our occupational health and safety and environmental audits include a review of your SDS library against the 16-section GHS format, with a list of sheets to replace and the risk assessments that need updating as a result. Contact us to discuss your site.
This article is general guidance, not legal advice. Check current legislation and regulations for your specific project.