The 16 Sections of a Safety Data Sheet

Every safety data sheet in the United States has the same sixteen sections, in the same order, because 29 CFR 1910.1200(g)(2) requires it. That standard order is the whole point of the format: whatever the product and whoever wrote the sheet, first aid is always Section 4 and exposure limits are always Section 8. Four of the sixteen, however, are not enforced by OSHA — and knowing which four tells you where a sheet is worth arguing about.

The detail that decides it — the four sections a worker actually needs in an emergency, the four OSHA does not enforce and why they are still there, and what Section 8 must contain that most people never check — is set out below.

1. The sixteen headings, in the required order

29 CFR 1910.1200(g)(2) requires the sheet to be in English and to include “at least the following section numbers and headings, and associated information under each heading, in the order listed”. The specific content of each section is set by Appendix D to the section, which is mandatory. The headings are:

1. Identification — the product identifier used on the label, recommended use and restrictions, the name, U.S. address and U.S. telephone number of the manufacturer or importer, and an emergency phone number.
2. Hazard(s) identification — the classification, and the signal word, hazard statements, symbols and precautionary statements that go on the label.
3. Composition/information on ingredients — chemical name, common names and synonyms, CAS number, and for mixtures the concentration or concentration range of the hazardous ingredients.
4. First-aid measures — broken down by route of exposure (inhalation, skin, eye, ingestion), the most important symptoms, and whether immediate medical attention is needed.
5. Fire-fighting measures — suitable and unsuitable extinguishing media, hazardous combustion products, and what fire-fighters need to wear.
6. Accidental release measures — personal precautions and protective equipment, and the methods and materials for containment and clean-up.
7. Handling and storage — safe handling precautions and safe storage conditions, “including any incompatibilities”.
8. Exposure controls/personal protection — exposure limits, engineering controls and PPE. See section 3 below; this one has a requirement people miss.
9. Physical and chemical properties — physical state, colour, odour, flash point, flammability limits, auto-ignition and decomposition temperature, pH, vapour pressure, density and more.
10. Stability and reactivity — reactivity, chemical stability, possible hazardous reactions, conditions to avoid, incompatible materials and hazardous decomposition products.
11. Toxicological information — routes of exposure, symptoms, immediate, delayed and chronic effects, numerical measures of toxicity, and whether the chemical is listed by the NTP, IARC or OSHA as a carcinogen.
12. Ecological information
13. Disposal considerations
14. Transport information
15. Regulatory information
16. Other information — “including date of preparation or last revision”. This is the line that tells you how old the sheet in your binder is.

2. The four sections OSHA does not enforce — and why they are still there

Sections 12 through 15 sit in an unusual position, and the standard says so twice. Note 1 to paragraph (g)(2) states that an SDS must include the headings in paragraphs (g)(2)(xii) through (g)(2)(xv) “in order” to be consistent with GHS. Note 2 states that “OSHA will not be enforcing information requirements in sections 12 through 15, as these areas are not under its jurisdiction”. Appendix D puts the same point plainly: sections 12–15 “may be included in the SDS, but are not mandatory”.

3. What Section 8 must contain that most people never check

Appendix D requires Section 8 to give, for every ingredient or constituent listed in Section 3, the OSHA permissible exposure limit (PEL), the ACGIH threshold limit value (TLV), and any other exposure limit used or recommended by the preparer, where available. It then requires appropriate engineering controls and individual protection measures.

That makes Section 8 the one place where a sheet connects a named ingredient to a number you can actually measure against — see what an OSHA PEL is and how to find it for what those numbers mean and where they come from. If you are choosing between two products, or defending a decision not to require a respirator, this is the section that carries the argument — not the PPE pictograms on the label.

4. The four sections a worker actually needs in an emergency

Sixteen sections is a lot to hand somebody whose eyes are stinging. In practice, four of them do the work at the moment of an incident:

• Section 4, First-aid measures — what to do, by route of exposure.
• Section 2, Hazard(s) identification — how bad is this, in one glance.
• Section 6, Accidental release measures — whether your people can clean it up at all. That question has its own answer: see incidental release or emergency response?
• Section 7, Handling and storage — the incompatibilities that caused the incident, and the ones that would make it worse. See chemical storage compatibility for a small facility.

Sections 9 through 11 are for the person writing the risk assessment, not the person holding the mop. Both audiences are legitimate; they just need the sheet at different moments.

5. An empty subheading has to say it is empty

Paragraph (g)(3) requires that if no relevant information is found for any sub-heading within a section, the preparer “shall mark it to indicate that no applicable information was found”. Appendix D repeats it: the SDS shall clearly indicate that no applicable information is available.

This is a small rule with a practical use. A blank space under a heading is ambiguous — it could mean “not applicable” or it could mean the preparer stopped. “No data available” is an answer; nothing at all is a gap, and it is a fair thing to query with a supplier.

6. What the sixteen sections do not tell you

They do not tell you whether the sheet is current. There is no expiry date anywhere in the format; the only clue is the date of preparation or last revision in Section 16 (see where to find the revision date and SDS number). See do safety data sheets expire? for what the standard actually requires about keeping sheets up to date.

They also do not tell you whether you have a sheet for every product on site — that is paragraph (g)(1), and it is the duty behind building a chemical inventory.

Frequently asked questions

What are the 16 sections of a safety data sheet?

In order: 1 Identification, 2 Hazard(s) identification, 3 Composition/information on ingredients, 4 First-aid measures, 5 Fire-fighting measures, 6 Accidental release measures, 7 Handling and storage, 8 Exposure controls/personal protection, 9 Physical and chemical properties, 10 Stability and reactivity, 11 Toxicological information, 12 Ecological information, 13 Disposal considerations, 14 Transport information, 15 Regulatory information, 16 Other information including date of preparation or last revision. 29 CFR 1910.1200(g)(2) requires those headings, in that order, in English.

Does OSHA enforce all 16 sections?

No. Note 2 to paragraph (g)(2) states that OSHA will not be enforcing the information requirements in sections 12 through 15, as those areas are not under its jurisdiction, and Appendix D says sections 12-15 may be included but are not mandatory. The headings still belong on the sheet so that it is consistent with GHS; the content under them is the business of other agencies.

What must Section 8 of an SDS contain?

Appendix D requires Section 8 to give, for every ingredient or constituent listed in Section 3, the OSHA permissible exposure limit (PEL), the ACGIH threshold limit value (TLV) and any other exposure limit used or recommended by the preparer, where available, plus appropriate engineering controls and individual protection measures.

What if a section of the SDS has no information?

It must say so. 1910.1200(g)(3) requires the preparer to mark a subheading to indicate that no applicable information was found, and Appendix D repeats that the sheet shall clearly indicate when no applicable information is available. A blank space is ambiguous; 'no data available' is an answer.

Which SDS sections matter in an actual emergency?

Section 4 first-aid measures, Section 2 hazard identification, Section 6 accidental release measures and Section 7 handling and storage, including incompatibilities. Sections 9 to 11 are written for whoever prepares the risk assessment rather than for the person responding at the time.

Related guides

• OSHA safety data sheet requirements for employers
• Where to find the SDS number, revision date and CAS number
• SDS vs MSDS: what changed
• Do you have to pay for safety data sheets?
• Does OSHA require SDS software?
• How long you must keep safety data sheets
• How to build a chemical inventory
• The GHS pictograms explained