Appendix C — A Primer on Safety Data Sheets

Safety Data Sheets (SDSs) are a publication that is mandated by the U.S. Occupational Safety and Health Administration (OSHA) under the 2012 revision of Hazard Communication Standard (HCS) (29 CFR 1910.1200(g)) (U.S. Occupational Health and Safety Adminstration (2012)). Under the HCS, manufacturers of substances and mixtures or substances (for example, consumer products) are required to communicate the hazards of chemical in the substance or mixture to downstream users. SDSs have many different uses ranging from allowing those using chemicals in the lab to know how substances may behave and to take appropriate precautions to informing consumers of the hazards of chemicals in a purchased consumer product. While the SDS are required to have 16 different sections, the section of most use within chemical exposure modeling (and currently with ChemExpo) is Section 3: Composition/Information on Ingredients. In this section, the HCS requires manufacturers to provide the information about each component covered by the SDS:

Some points to call attention to here are that 1) if a substance in a product does not pose a known health hazard, it does not have to be reported on the SDS, and 2) if a product is considered an “article” no information on the SDS must be reported. For reference an article is defined in the HCS as following:

a manufactured item: (i) which is formed to a specific shape or design during manufacture; (ii) which has end use function(s) dependent in whole or in part upon its shape or design during end use; and (iii) which does not release, or otherwise result in exposure to, a hazardous chemical under normal conditions of use.

It should also be noted that while the HCS does require exact percentages of chemicals, their impurities, and any stabilizing additives be reported on SDSs, there are several exemptions available for chemicals in a mixture. Namely, manufacturers are allowed to report a range of concentration for chemicals in that mixture if the manufacturer claims there is a trade secret, there may be variations from one batch of product to the next, or if the SDS is used for products which are very similar in composition.

Due to these exceptions and exemptions available for both mixtures and articles under the HCS, users may note that there are products in ChemExpo for which there are no chemical cards. This is either typically because there were no reported chemicals on the SDS because it was a consumable product and no ingredients were considered a hazard to human health or because the product is considered an “article” and requires no reporting.

Further, users of ChemExpo may notices that some chemical substances reported in ChemExpo from SDS have a range for a chemical’s composition rather than a single value. This happens due to one of the exemptions to reporting the exact chemical concentration for chemical mixtures.

For more information about what an SDS is and what information is contained within the SDS, see the OSHA Brief on Safety Data Sheets.