SDS Section by Section: All 16 Sections of a Safety Data Sheet (and the Ones OSHA Won't Enforce)

A Safety Data Sheet (SDS) has exactly 16 sections in a fixed order, defined by OSHA's Hazard Communication Standard at 29 CFR 1910.1200(g) and Appendix D. Sections 1-11 and 16 are fully enforceable by OSHA; Sections 12-15 are not OSHA-enforced because they cover information governed by other agencies (EPA, DOT). Knowing which sections matter for an OSHA inspection - and which ones an inspector will skip - is the fastest way to keep your SDS library citation-proof.

Why the 16-Section Format Exists

Before 2012, chemical hazard documents were free-format "MSDS" sheets - every manufacturer organized them differently, which slowed down workers and emergency responders in a crisis. The 2012 HazCom update aligned the U.S. with the Globally Harmonized System (GHS), mandating a single, predictable 16-section layout so the same data always appears in the same place.

All 16 SDS Sections at a Glance

The Sections OSHA Will Actually Cite

Under 1910.1200(g)(2), the SDS must contain the information for Sections 1-11 and 16. Sections 12-15 sit outside that duty: Appendix D states they may be included but are not mandatory, and Note 2 to (g)(2) explains why — “OSHA will not be enforcing information requirements in sections 12 through 15, as these areas are not under its jurisdiction”, because:

• Section 12 (Ecological) falls to the EPA.
• Section 13 (Disposal) is governed by EPA/RCRA.
• Section 14 (Transport) is governed by the U.S. DOT.
• Section 15 (Regulatory) spans multiple agencies.

This is the single most misunderstood point about SDS compliance: in practice virtually every sheet carries all 16 headings, because the UN GHS format calls for them and (g)(2) lists them in order — but Appendix D does not make 12-15 mandatory, and OSHA will not write a citation if the content under those headings is thin. Where OSHA does focus is the hazard-driven sections - especially Section 2 (classification), Section 8 (exposure limits and PPE), and Section 1 (a working emergency contact).

Section-by-Section: What Inspectors Look For

Section 1 - Identification. Must list the product identifier used on the label; the name, U.S. address and U.S. telephone number of the manufacturer, importer or other responsible party; and an emergency phone number (Appendix D, Section 1). A blank or disconnected emergency number defeats the purpose of the section.

Section 2 - Hazard Identification. The heart of GHS classification: signal word ("Danger" or "Warning"), hazard statements (H-codes), precautionary statements (P-codes), and pictograms. Remember OSHA requires eight pictograms; the GHS09 environmental pictogram is voluntary and is not an OSHA-required symbol.

Section 3 - Composition. Hazardous ingredients with chemical names and CAS numbers. Trade-secret withholding is allowed only under the narrow conditions of 1910.1200(i).

Section 8 - Exposure Controls / PPE. Lists permissible exposure limits (PELs). Verify these against current OSHA limits - for example, the construction silica PEL is 50 µg/m³ with a 25 µg/m³ action level under 1926.1153.

Section 16 - Other Information. Must show the date of preparation or last revision. An SDS with no revision date is the classic sign of a stale library.

The other required sections, item by item

Appendix D to 29 CFR 1910.1200 lists what each of the remaining mandatory sections must hold. Read against a sheet in your library, it is a quick completeness check:

• Section 4, First-aid measures: the necessary measures by route of exposure (inhalation, skin and eye contact, ingestion), the most important symptoms and effects, acute and delayed, and any immediate medical attention or special treatment needed.
• Section 5, Fire-fighting measures: suitable and unsuitable extinguishing media, specific hazards arising from the chemical such as hazardous combustion products, and special protective equipment and precautions for fire-fighters.
• Section 6, Accidental release measures: personal precautions, protective equipment and emergency procedures, and the methods and materials for containment and cleaning up.
• Section 7, Handling and storage: precautions for safe handling and conditions for safe storage, including any incompatibilities.
• Section 9, Physical and chemical properties: a list that runs from physical state, color and odor to flash point, flammability limits, pH, vapor pressure, density and particle characteristics.
• Section 10, Stability and reactivity: reactivity, chemical stability, the possibility of hazardous reactions, conditions to avoid, incompatible materials and hazardous decomposition products.
• Section 11, Toxicological information: likely routes of exposure, symptoms, delayed, immediate and chronic effects, numerical measures of toxicity, and whether the chemical is listed by NTP or IARC, or by OSHA, as a carcinogen.

A sheet that skips one of these items is incomplete under 29 CFR 1910.1200(g)(2), whoever prepared it, and the fix is a request to the manufacturer for a complete sheet.

Who provides the SDS, and when

The sheet has to reach you, and OSHA is specific about the chain. Under 1910.1200(g)(6), the chemical manufacturer or importer must provide an SDS with the first shipment of a hazardous chemical, and again with the first shipment after the SDS is updated with significant new information. Under (g)(7), distributors carry the same duty downstream to other distributors and employers. You should not have to ask for the initial sheet — it is supposed to arrive with the product.

If it doesn't, the duty flips to you: under 1910.1200(g)(6)(iii) the distributor or employer must obtain one from the chemical manufacturer or importer as soon as possible — and under (g)(6)(iv) the manufacturer or importer must provide one upon request. Put the request in writing and keep the record. And the sheet must be in English (other languages may be added) under (g)(2); an SDS supplied only in another language does not satisfy the standard. The full recovery process is in Supplier won't provide an SDS?.

SDS vs. Label vs. MSDS

SDS Compliance Checklist

• An SDS is on file for every hazardous chemical in your inventory
• Each sheet follows the 16-section order
• Sections 1-11 and 16 are complete and current
• Section 1 has a live emergency contact
• Sheets are readily accessible to employees on every shift (paper or reliable electronic access)
• Section 16 shows a revision date within a reasonable cycle
• A backup access method exists for power/internet outages

The standard, tools & related reading

• The standard: Hazard Communication — 29 CFR 1910.1200 · SDS Management hub
• Manage your library: SDS Gap Analyzer · SDS QR Code Generator · Chemical Inventory Template
• Related guides: How to Read a Safety Data Sheet · GHS Pictograms Explained · SDS Management Best Practices
• 2026 OSHA penalty schedule · penalties by state