Find the Holes: How to Conduct an SDS Library Gap Audit

The Hidden Liability

An SDS library is rarely perfect. Over time, "phantom chemicals" accumulate—products that are no longer on site—while new chemicals slip in without documentation. With the transition to GHS Revision 7, a new gap has emerged: documents that are technically present but regulatory obsolete. A Gap Analysis is the forensic audit process used to find and fix these holes.

Step 1: The Physical Inventory

You cannot analyze what you don't know you have. Walk the jobsite. Open every flammable cabinet, look under every workbench, and check every gang box.

Capture: Take a photo of the front and back label of every container.

List: Compile a master list of Product Names and Manufacturers.

Step 2: The Library Cross-Reference

Compare your physical list against your current SDS library (binder or digital).

Missing SDSs: Products found on site but not in the library. Action: Request immediately.

Ghost SDSs: Documents in the library for products no longer on site. Action: Move to Archive.

Step 3: The Revision Check (The 2026 Critical Step)

Check the revision date and format of each SDS.

Format: Is it a 16-section SDS or an old 9-section MSDS? MSDSs are non-compliant.

Revision: Look for GHS Rev 7 indicators (e.g., "Aerosol Category 3" instead of just "Pressurized Gas").

Signal Word: Does it match the label?

Step 4: The Action Plan

Prioritize your gaps.

Immediate: Missing SDSs for high-hazard chemicals (Category 1 Flammables, Acute Toxins).

Urgent: Obsolete MSDSs that need updating to GHS SDSs.

Scheduled: Updating Rev 3 SDSs to Rev 7 by the May 2026 manufacturer deadline.

A Gap Analysis should be conducted annually or at the start of every major project phase. It is the only way to ensure your "paper shield" has no holes.

Related: [SDS Gap Analyzer](/tools/sds-gap-analyzer) · [Chemical Inventory](/tools/chemical-inventory-template) · [SDS Management Best Practices](/blog/s