Chemicals and Safety Data Sheets

This is OSHA's own list, from Appendix D to 29 CFR 1910.1200. The numbers and headings are fixed; a manufacturer cannot renumber them or reorder them.

Section 1

Identification — product identifier, recommended use and restrictions on use, who made it, emergency phone number.

Section 2

Hazard(s) identification — classification, signal word, hazard statement(s), symbol(s) and precautionary statement(s).

Section 3

Composition / information on ingredients — chemical name, CAS number, and for a mixture, the ingredients classified as health hazards and how much of each.

Section 4

First-aid measures — by route of exposure, plus the symptoms that matter and when to get medical attention.

Section 5

Fire-fighting measures — suitable and unsuitable extinguishing media, and what the chemical gives off when it burns.

Section 6

Accidental release measures — the spill response.

Section 7

Handling and storage — "conditions for safe storage, including any incompatibilities".

Section 8

Exposure controls / personal protection — the OSHA permissible exposure limit, the ACGIH threshold limit value, engineering controls, PPE.

Section 9

Physical and chemical properties — physical state, odor, flash point, auto-ignition temperature, density, pH and the rest.

Section 10

Stability and reactivity — reactivity, conditions to avoid, "incompatible materials", hazardous decomposition products.

Section 11

Toxicological information — the health effects and the data behind them, including any carcinogen listings.

Section 12

Ecological information

Section 13

Disposal considerations

Section 14

Transport information

Section 15

Regulatory information

Section 16

Other information — "the date of preparation of the SDS or the last change to it".

Twelve through fifteen are the odd ones out. The headings have to be there: a note to the standard says an SDS "must also include the headings" for those four, "in order", to stay consistent with the international system the format comes from. What goes under them is a different question. Appendix D says "Sections 12-15 may be included in the SDS, but are not mandatory", and a second note to the same paragraph says "OSHA will not be enforcing information requirements in sections 12 through 15, as these areas are not under its jurisdiction."

Those four cover the environment, waste, shipping and other agencies' regulations — EPA and DOT ground, not OSHA's. So Section 13 tells you what the manufacturer suggests doing with the leftovers. It does not tell you what happens to them here. Ask.

Two more things about the shape of the document. The section order is fixed but the order within a section is not — preparers "are not required to present the information in any particular order within each section", so two sheets can look different inside the same numbered box. And a heading with nothing under it is not an oversight: where there is no relevant information, "the SDS shall clearly indicate that no applicable information is available." Read that as nobody has the data — not as nothing to worry about.

There are exactly two signal words, and OSHA defines them in 1910.1200(c): a signal word indicates "the relative level of severity of hazard", and "'Danger' is used for the more severe hazards, while 'warning' is used for the less severe."

Severity is relative to the same kind of hazard, and that is the part that catches people. Flammable liquids in OSHA's Appendix C are the clean example — all three categories carry the same Flame pictogram, and the signal word is the only thing separating them:

Category 1

Danger — "Extremely flammable liquid and vapor"

Category 2

Danger — "Highly flammable liquid and vapor"

Category 3

Warning — "Flammable liquid and vapor"

So “warning” does not mean mild. A Category 3 flammable liquid still catches fire. The signal word ranks a hazard against others of its own kind; it is not a statement that the chemical is safe.

The pictograms are a fixed set of eight — a black symbol in a red-bordered diamond standing on a point. OSHA names them: Flame, Flame Over Circle, Exclamation Mark, Exploding Bomb, Corrosion, Gas Cylinder, Health Hazard, and Skull and Crossbones.

The H-numbers are an index, not the warning. Real sheets often print a code such as H225 beside a hazard statement. Those codes come from the international GHS scheme this format is built on, which treats them as reference labels rather than as a substitute for the statement itself. OSHA's Appendix C does not use them at all — it specifies the sentence. Read the sentence.

Section 16 carries "the date of preparation of the SDS or the last change to it." That is the only date on the document, and it is how you tell a live sheet from one that has sat in a binder for a decade.

Keeping it current is the manufacturer's job, not yours. Under 1910.1200(g)(5), when a manufacturer or importer "becomes newly aware of any significant information regarding the hazards of a chemical, or ways to protect against the hazards, this new information shall be added to the safety data sheet within three months."

OSHA calls it a storage cabinet and defines it by a fire test rather than by how solid it looks. 29 CFR 1910.106(d)(3) requires cabinets to "limit the internal temperature to not more than 325 °F. when subjected to a 10-minute fire test", with all joints and seams staying tight and the door staying closed throughout.

The same paragraph requires the marking, which is the fastest way to recognise one: "Cabinets shall be labeled in conspicuous lettering, 'Flammable - Keep Fire Away.'"