MSDS vs. SDS: Updated Requirements, Format Changes, and Compliance Tips

At a Glance

• MSDS and SDS mean the same thing in terms of purpose but differ significantly in format and standardization
• The primary difference is that SDSs follow a mandatory 16-section format while MSDSs varied widely
• OSHA adopted GHS standards in 2012 with full compliance required by June 1, 2015
• Sections 1-11 and 16 are mandatory in SDSs; sections 12-15 are included but not OSHA-enforced
• SDSs include standardized signal words (Warning/Danger), hazard pictograms, and hazard statements
• Chemical manufacturers must update SDSs within 90 days of discovering significant new hazard information
• Employers can maintain old MSDSs for chemicals received before June 2015 until receiving updated SDSs
• The latest OSHA updates (HazCom 2024) have new compliance deadlines through 2027

Chemical safety documentation has undergone a significant transformation over the past decade. If you’ve worked with hazardous materials for any length of time, you’ve probably noticed that Material Safety Data Sheets (MSDS) have been replaced by Safety Data Sheets (SDS). This change represents much more than a simple name adjustment. The shift reflects a global effort to standardize how chemical hazards are communicated across borders, industries, and languages.

In 2012, OSHA aligned with the Globally Harmonized System (GHS) of Classification and Labeling of Chemicals, and the term “MSDS” was officially replaced with “SDS”. This transition standardized chemical safety communication worldwide and introduced a consistent 16-section format that replaced the variable formats previously used.

Understanding the differences between MSDS and SDS matters for workplace safety, regulatory compliance, and international trade. Whether you’re a safety manager updating your chemical inventory system, an employee working with hazardous materials, or a business importing or exporting chemicals, knowing these requirements helps maintain compliance and protect workers.

What MSDS and SDS Mean: The Name Change Explained

MSDS stands for Material Safety Data Sheet and, much like an SDS, it is a document that provides detailed information about the potential hazards of a chemical product, as well as instructions for its safe handling, storage, and disposal. These documents served as the foundation of chemical safety communication in the United States for decades.

SDS stands for Safety Data Sheet, which is a comprehensive document that provides crucial information about the hazards of chemicals, as well as safety precautions for their handling, storage, and disposal. The content goals remain identical. Both document types aim to inform workers about chemical hazards and protective measures.

So do MSDS and SDS mean the same thing? Functionally, yes. Both serve the same purpose of hazard communication. However, the main difference between an MSDS and an SDS is the standardized formatting, with all SDSs following the GHS’s 16 section formatting, while MSDSs could come in many different formats depending on the organization.

Quick Comparison:

Aspect	MSDS	SDS
Format	Variable (typically 8-12 sections)	Standardized (16 sections)
Global recognition	Limited	Universal under GHS
Section order	Not standardized	Mandatory sequence
Signal words	Not required	Required (Warning/Danger)
Pictograms	Varied by manufacturer	Standardized GHS symbols
Current status	Phased out (legacy documents)	Current standard

The Globally Harmonized System: Why the Change Happened

The Globally Harmonized System of Classification and Labelling of Chemicals also known as GHS is an internationally agreed-upon standard managed by the United Nations that was set up to replace the assortment of hazardous material classification and labelling schemes previously used around the world.

Before GHS implementation, chemical manufacturers faced a complex regulatory landscape. A chemical classified as hazardous in one country might not be classified the same way elsewhere. Labeling requirements differed between regions. MSDSs could include different kinds of information with different levels of detail, whereas the SDS format is more in-depth.

This inconsistency created several problems:

• Workers handling imported chemicals received unfamiliar safety information
• Emergency responders couldn’t quickly locate critical information during incidents
• Companies operating internationally maintained multiple documentation systems
• Training programs varied widely in quality and content
• Chemical classification criteria differed between jurisdictions

The Globally Harmonized System of Classification and Labeling of Chemicals was developed by the United Nations to standardize the classification of chemicals across all nations and aims to make sure that information about hazards is consistent and clearly communicated across the globe.

The 16-Section SDS Format: What Changed

SDSs now have a standard 16-section format with signal words (Warning or Danger), universally standardized hazard and precautionary statements, and hazard pictograms. This standardization represents the most visible change from MSDS to SDS.

The 16 Required Sections:

1. Identification – Product identifier, manufacturer information, recommended use
2. Hazard Identification – Hazard classification, signal words, hazard statements, pictograms
3. Composition/Ingredients – Chemical ingredients and their concentrations
4. First Aid Measures – Emergency treatment procedures for exposure
5. Fire-Fighting Measures – Extinguishing techniques and combustion hazards
6. Accidental Release Measures – Spill response procedures and containment methods
7. Handling and Storage – Safe handling precautions and storage requirements
8. Exposure Controls/Personal Protection – Exposure limits, engineering controls, PPE requirements
9. Physical and Chemical Properties – Appearance, odor, pH, boiling point, flash point, etc.
10. Stability and Reactivity – Chemical stability and incompatible materials
11. Toxicological Information – Health effects from exposure routes
12. Ecological Information – Environmental impact data (not OSHA-enforced)
13. Disposal Considerations – Waste disposal methods (not OSHA-enforced)
14. Transport Information – Shipping classification and requirements (not OSHA-enforced)
15. Regulatory Information – Applicable regulations (not OSHA-enforced)
16. Other Information – Preparation date and revision information

Since other Agencies regulate this information, OSHA will not be enforcing Sections 12 through 15. These sections must be included for GHS consistency, but the EPA and DOT handle enforcement of environmental, disposal, and transportation requirements.

Key Format Improvements Over MSDS

Signal Words: SDSs, unlike MSDSs, now have signal words, these include Warning – which means a less serious hazard, and Danger – which means a more serious hazard. This immediate visual cue helps workers quickly assess risk severity.

Hazard Pictograms: Hazard pictograms are now red and white symbols or a Red Square tilted 45° on a point. The standardized pictograms include:

• Flame (flammable materials)
• Flame over circle (oxidizers)
• Gas cylinder (compressed gases)
• Corrosion (corrosive materials)
• Skull and crossbones (acute toxicity)
• Exploding bomb (explosives)
• Health hazard (serious health effects)
• Exclamation mark (irritants)
• Environment (aquatic toxicity)

Standardized Statements: Hazard statements and precautionary statements now use consistent wording across all SDSs. Risk phrases have become Hazard Statements (“H-statements”) and safety phrases are now Precautionary Statements (“P-statements”). Each statement has a unique code (like H302 or P264) that can be understood globally.

Compliance Timeline and Transition Requirements

Since OSHA established its 1994 Hazard Communication guidelines, the 8-section MSDS has been the most commonly used MSDS format across the United States. The transition to SDS followed a phased implementation schedule.

Historical Timeline:

Date	Requirement
March 26, 2012	OSHA published final HazCom 2012 rule
December 1, 2013	Employee training on new label elements and SDS format required
June 1, 2015	Chemical manufacturers must comply with all provisions
June 1, 2015	Employers must update hazard communication programs
June 1, 2016	Distributors must comply with all provisions

Manufacturers and importers must provide revised, 16-section SDSs by June 1, 2015, with the chemical manufacturer or importer required to provide the updated SDSs with the first shipment after a safety data sheet is updated or upon request.

Current Status: An employer who is maintaining an MSDS for a product received prior to June 1, 2015, would be considered to be compliant with the Hazard Communication standard unless the manufacturer, importer or distributor has provided a new, HCS 2012-compliant SDS. Legacy MSDSs can remain in use for older chemical inventory until suppliers provide updated SDSs.

Recent Updates: HazCom 2024

OSHA continues updating the Hazard Communication Standard. This section shall become effective July 19, 2024, with manufacturers, importers, and distributors evaluating substances in compliance with all modified provisions of this section no later than January 19, 2026.

New Compliance Deadlines:

• January 19, 2026 – Substance manufacturers/importers must comply with all HazCom 2024 modifications
• July 20, 2026 – Employers must update workplace labeling and provide additional training
• July 19, 2027 – Mixture manufacturers/importers must comply with all provisions

These updates include refined classification criteria, updated concentration ranges for trade secret claims, and new labeling requirements for small containers.

Practical Compliance Tips for Employers

Maintaining SDS Accessibility: SDS must be readily accessible to employees at all times (paper or electronic). OSHA permits electronic storage as long as workers can access SDSs immediately during their work shift without barriers like passwords, system downtime, or lack of equipment access.

Update Requirements: SDS must be updated within 90 days of receiving significant new hazard information. Chemical manufacturers and importers must revise SDSs when they become aware of new data affecting hazard classification or protective measures.

Retention Requirements: SDS (or acceptable exposure records) must be retained for 30 years. This extended retention period supports long-term health monitoring for workers who may develop chronic conditions from chemical exposure.

Managing the Transition:

1. Don’t discard old MSDSs immediately
   
   • Archive old MSDSs as they get replaced by SDSs, with incoming SDSs needing to be checked against the older MSDSs to see if there are any new hazards or precautions
   • Some chemicals may have undergone classification changes under GHS criteria
2. Implement systematic replacement procedures
   
   • Request updated SDSs from all chemical suppliers
   • Track which products have current SDS documentation
   • Establish procedures for reviewing incoming SDSs
3. Update chemical inventory systems
   
   • Ensure database fields accommodate 16-section format
   • Link SDSs to chemical products in inventory tracking
   • Enable quick searches by product name, CAS number, or hazard class
4. Train employees on SDS format
   
   • Explain the 16-section structure and where to find specific information
   • Review new hazard pictograms and signal words
   • Practice locating emergency information quickly
5. Coordinate with suppliers
   
   • OSHA recognizes that some manufacturers and importers may be unable to create updated SDSs because they have not received the necessary information from upstream suppliers to classify and develop their own SDSs
   • Document efforts to obtain updated SDSs from suppliers

International Considerations

Many regions have adopted GHS to varying degrees, however, each nation may have slight variations in their implementation, as countries have adopted different versions of the GHS and some have implemented it either fully or partially.

Companies operating internationally should note:

• The EU implemented GHS through CLP (Classification, Labeling and Packaging) Regulation
• Canada adopted GHS requirements effective January 2023
• Australia, New Zealand, and many Asian countries have implemented GHS
• GHS revisions continue (currently at Rev. 9), with countries adopting different revision levels

Managing Chemical Documentation with Elchemy

For businesses dealing with multiple chemical suppliers or managing extensive chemical inventories, maintaining current SDS documentation becomes a significant administrative task. Elchemy helps companies source chemicals from qualified suppliers who provide complete, up-to-date SDS documentation in GHS-compliant formats. Whether you’re procuring industrial chemicals, specialty compounds, or raw materials, we connect you with suppliers that maintain proper safety documentation and regulatory compliance across international standards. Our network includes manufacturers providing SDSs that meet OSHA, REACH, and other regional requirements, helping streamline your hazard communication program management.

Conclusion

The transition from MSDS to SDS represents more than bureaucratic name-changing. The standardized 16-section format improves safety by making critical information easier to locate during emergencies, training simpler through consistent terminology, and compliance more straightforward through clear requirements. While the transition period created administrative challenges, the long-term benefits of harmonized chemical safety communication justify the effort. As OSHA continues refining the Hazard Communication Standard through updates like HazCom 2024, staying current with SDS requirements remains essential for workplace safety and regulatory compliance.

FAQs

Can I still use electronic SDSs?
Yes. Electronic storage is acceptable provided employees can access SDSs immediately without barriers. Systems must allow printing, searching by chemical name, and 24/7 availability during work shifts.

Do I need to resubmit SDSs to emergency responders?
If the hazard classification changes based on the OSHA HCS revisions to incorporate the GHS criteria, facilities that originally submitted MSDSs (SDSs) must subsequently submit a revised MSDS (SDS) to the LEPC, the SERC, and the local fire department. Format changes alone don’t require resubmission unless hazard classifications changed.

What if my supplier sends an MSDS instead of SDS?
If chemicals received directly from foreign manufacturers after June 1, 2015, are not accompanied by SDSs which comply with the revised standard, the importer becomes responsible for ensuring compliance. Contact suppliers to request updated SDSs and document these efforts.

How do I handle trade secrets on SDSs?
Nothing in this paragraph shall be construed as requiring the disclosure under any circumstances of process information which is a trade secret. However, HazCom 2024 introduced new concentration ranges for trade secret claims in Section 3.2 while still requiring essential hazard information disclosure.