Supplying chemical substances and mixtures in the United States requires compliance with a regulatory framework that differs from that of the European Union. Although both systems are based on the Globally Harmonized System of Classification and Labelling of Chemicals (GHS), a Safety Data Sheet (SDS) prepared in accordance with the REACH Regulation does not automatically guarantee compliance with US legislation.

In the United States, Safety Data Sheets (SDSs) are regulated by the Hazard Communication Standard (HazCom) of the Occupational Safety and Health Administration (OSHA). This standard sets out how hazards must be classified, what information must be included in SDSs, and the obligations of manufacturers, importers, distributors and employers to communicate chemical hazards in the workplace.

In addition, OSHA updated the Hazard Communication Standard in 2024 to align it primarily with the seventh revision of the GHS (GHS Rev. 7) and to introduce new requirements relating to the classification of certain hazards, the content of labels and SDSs, and a transition schedule for implementation.

For companies exporting chemicals to the United States, understanding these differences is essential to avoid regulatory non-compliance, facilitate hazard communication and ensure that the SDSs supplied meet OSHA requirements.

In this guide, you will find:

• The regulations governing SDSs in the United States.
• When providing a Safety Data Sheet is mandatory.
• The differences compared with a European SDS.
• The specific requirements established by OSHA.
• The changes introduced by the update to HazCom 2024.
• Best practices for keeping SDSs up to date and compliant.

Summary

Key takeaway

A REACH-compliant Safety Data Sheet does not guarantee compliance with OSHA’s Hazard Communication Standard. Before marketing a chemical product in the United States, it is necessary to check that the SDS meets the specific requirements set out in 29 CFR 1910.1200.

Which regulations govern Safety Data Sheets in the United States?

SDS regulations in the United States are primarily based on the Hazard Communication Standard (HCS or HazCom), developed by the Occupational Safety and Health Administration (OSHA).

The purpose of this standard is to ensure that workers are aware of the hazards associated with chemicals in their workplace through a standardized system of classification, labelling and documentation.

Although the Hazard Communication Standard adopts the principles of the GHS developed by the United Nations, the United States maintains its own regulations, so the applicable obligations are not identical to those set out in the REACH Regulation or the CLP Regulation.

Occupational Safety and Health Act

The legal basis for the Hazard Communication Standard is the Occupational Safety and Health Act of 1970 (OSH Act).

This Act established OSHA and gave the agency the authority to develop standards to protect workers’ health and safety against occupational risks, including exposure to hazardous chemicals.

In this context, effective chemical hazard communication is one of the fundamental pillars of US occupational health and safety legislation.

OSHA Hazard Communication Standard (29 CFR 1910.1200)

The Hazard Communication Standard, codified in 29 CFR 1910.1200, is the main standard governing Safety Data Sheets in the United States.

Among other things, it establishes:

• the criteria for classifying physical and health hazards
• the obligations of manufacturers and importers
• labelling requirements
• the content and format of SDSs
• employers’ obligations to ensure that workers have access to information about chemicals present in the workplace

Since the 2012 update, OSHA has required SDSs to follow a standardized 16-section format, aligned with the GHS. The revision published in 2024 retains this structure but introduces changes to certain classification criteria, labelling requirements and technical content to improve alignment with GHS Rev. 7, as well as with other trading partners, including Canada.

Hazard Communication Standard 2024 (HazCom 2024)

In May 2024, OSHA published the most significant update to the Hazard Communication Standard since the 2012 revision.

The main objectives of this amendment are to:

• improve chemical hazard communication
• align US regulatory requirements with the seventh revision of the GHS
• update certain classification criteria
• introduce improvements to labels and SDSs
• facilitate international trade through greater regulatory convergence

Among other changes, the update includes:

• changes to certain hazard classes and categories
• new requirements for some small containers
• changes relating to the protection of trade secrets
• adjustments to the content of certain SDS sections

OSHA has established a transition period to allow manufacturers, importers, distributors and employers to gradually adapt their labels, Safety Data Sheets and hazard communication programs to the new standard.

Competent authority

Occupational Safety and Health Administration (OSHA)

The Occupational Safety and Health Administration (OSHA) is the federal authority responsible for developing and enforcing the Hazard Communication Standard.

Its main responsibilities include:

• developing hazard communication regulations
• publishing technical guidance and official interpretations
• monitoring compliance by manufacturers, importers and employers
• promoting workers’ protection against exposure to hazardous chemicals

OSHA also publishes technical documentation, frequently asked questions and supporting materials to facilitate the proper implementation of the Hazard Communication Standard and SDS-related obligations.

What is the relationship between OSHA, the GHS and REACH?

One of the most common questions among European companies is whether a Safety Data Sheet prepared in accordance with the REACH Regulation can be used directly in the United States.

The answer is not necessarily.

Although the Hazard Communication Standard is based on the Globally Harmonized System (GHS), OSHA independently decides which GHS revisions to incorporate into its regulations and how to adapt them to the US regulatory framework.

As a result, a European SDS may share much of its structure with a US SDS but still require changes to fully comply with the Hazard Communication Standard.

Differences may affect aspects such as:

• the classification criteria for certain hazards;
• the information required in some SDS sections;
• labelling requirements;
• manufacturer or importer information;
• certain provisions relating to trade secrets or workplace hazard communication.

Consequently, companies exporting chemicals to the United States should review their Safety Data Sheets before placing products on the market to check that they meet OSHA’s requirements.

When is an SDS mandatory in the United States?

Determining when a Safety Data Sheet must be supplied is one of the first steps in ensuring compliance with the Hazard Communication Standard (HazCom).

In the United States, the obligation to provide an SDS falls primarily on manufacturers and importers of hazardous chemicals, who must prepare or obtain an SDS for each hazardous chemical they produce or import and ensure that the required hazard information is transmitted downstream.

The aim is to ensure that distributors, employers and workers have clear, up-to-date information about the product’s hazards and the measures needed to handle it safely.

Which products require an SDS?

As a general rule, OSHA requires a Safety Data Sheet for all hazardous chemicals covered by the Hazard Communication Standard.

This obligation applies to both substances and mixtures that present physical hazards, health hazards or, following the HazCom 2024 update, certain additional hazards covered by the regulations.

The SDS must be prepared and provided as required when the hazardous chemical is shipped or distributed, and must remain accessible where required under HazCom.

Who must prepare the SDS?

The primary responsibility lies with the manufacturer or the importer of the chemical product.

These parties must:

• assess the product’s hazards;
• classify it in accordance with HazCom;
• prepare the SDS;
• update it when significant new information becomes available;
• supply it to distributors and downstream employers, as required.

Distributors, in turn, must ensure that the SDS accompanies the product when it is supplied to the next link in the chain.

What obligations do employers have?

An important difference compared with European regulations is that the Hazard Communication Standard also establishes specific obligations for employers.

Companies using hazardous chemicals in the workplace must ensure that:

• all SDSs are available to workers during their working hours;
• employees know how to access them;
• a Hazard Communication Program is in place;
• workers receive training on the hazards associated with chemicals to which they may be exposed in their work areas and on appropriate protective measures.

In other words, OSHA regulates both the preparation of SDSs and their effective use as a hazard communication tool.

When must an SDS be updated?

The obligation to keep an SDS up to date continues after the product has been placed on the market.

Manufacturers and importers must review the documentation when they have significant new information relating to:

• physical hazards
• health hazards
• protective measures
• product classification
• toxicological data
• handling or storage recommendations

The update must be completed within the time limits established by the Hazard Communication Standard and communicated to recipients when necessary.

This requirement is particularly important following the entry into force of HazCom 2024, as many companies will need to review their SDSs to adapt them to the new regulatory criteria.

Specific requirements for Safety Data Sheets in the United States

Although US SDSs have a structure very similar to those used in the European Union, OSHA establishes its own requirements that must be checked before marketing a product.

16-section format

Since the 2012 update to the Hazard Communication Standard, all SDSs must follow a standardized format of 16 sections, aligned with the Globally Harmonized System (GHS).

The sections are:

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.

Although OSHA does not require the content of sections 12 to 15, these must remain in the SDS to preserve the international 16-section structure.

This is one of the main similarities with SDSs prepared in accordance with REACH.

Language

OSHA does not explicitly require SDSs to be written exclusively in English.

However, in practice, the documentation must be available in a language that enables workers to understand the hazard information and use it effectively.

Since the vast majority of workplaces in the United States use technical documentation in English, this is the language normally used for Safety Data Sheets.

Multinational companies often maintain additional versions in other languages to facilitate worker training or international distribution, provided that this does not replace compliance with OSHA’s requirements.

Manufacturer or importer identification

Section 1 of the SDS must clearly identify the party responsible for the product.

Among other details, it must include:

• manufacturer, importer or other responsible party name
• address
• contact telephone number
• recommended use of the product
• restrictions on use, where applicable
• emergency telephone number

The information must be kept up to date to ensure that users can quickly contact the responsible party in the event of an incident.

Hazard classification

Manufacturers and importers are responsible for correctly classifying chemicals according to OSHA’s criteria.

The HazCom 2024 update introduces changes to certain hazard classes and categories with the aim of aligning with the seventh revision of the GHS.

As a result, many companies will need to review their product classifications and check whether these also affect the content of their SDSs.

Trade secrets

One distinctive feature of US legislation is the treatment of trade secrets.

Under certain circumstances, OSHA allows the specific chemical identity or exact concentration of an ingredient to be protected when it constitutes a legitimate trade secret.

However, this protection does not remove the obligation to provide sufficient information to ensure the safe use of the product, and specific procedures exist for providing information to healthcare professionals or authorities when necessary.

This approach differs in some respects from that applied in the European Union and must be taken into account when adapting a European SDS for the US market.

SDS retention and access

Employers must ensure that all Safety Data Sheets remain readily accessible to workers during each work shift.

SDSs may be kept electronically, provided that employees have immediate access to them when needed.

They must also be integrated into the hazard communication program required by the Hazard Communication Standard.

Updating SDSs

SDS updates should not be limited to regulatory changes. An update will also be necessary when:

• new toxicological data become available
• new hazards emerge
• the product classification changes
• handling or storage recommendations are modified
• new regulatory requirements enter into force, such as those arising from HazCom 2024

For companies managing hundreds or thousands of products, keeping this documentation up to date can become a complex process, especially when the same formulation must be marketed in different countries with different regulatory requirements.

Differences between European and US SDSs

At first glance, a Safety Data Sheet prepared in accordance with the REACH Regulation may appear almost identical to one used in the United States. Both follow a 16-section structure and are based on the Globally Harmonized System (GHS).

However, there are important regulatory differences to consider before using a European SDS in the US market.

The main difference is that the United States does not apply REACH or CLP. Obligations relating to classification, labelling and Safety Data Sheets are governed by the Hazard Communication Standard (29 CFR 1910.1200), developed by OSHA.

This means that a REACH-compliant SDS may require changes to meet HazCom’s classification criteria, terminology and specific requirements.

Comparison between European Union and US SDSs

What does this mean in practice?

For many European companies, an SDS prepared in accordance with REACH provides a good documentary starting point. However, before exporting a product to the United States, it is advisable to review aspects such as:

• classification in accordance with HazCom
• label elements
• manufacturer or importer information
• the terminology used
• consistency with OSHA requirements
• the changes introduced by HazCom 2024

In other words, adapting an SDS for the United States does not usually mean writing an entirely new document, but it does require careful verification that it meets US regulatory requirements.

Recent regulatory changes: HazCom 2024

The update to the Hazard Communication Standard published by OSHA in 2024 represents the most significant change to US hazard communication regulations since the adoption of the GHS in 2012.

Its main purpose is to improve chemical hazard communication and increase international harmonization, particularly with the more recent revisions of the GHS.

The main changes include:

Alignment with GHS Revision 7

HazCom 2024 aligns the US Hazard Communication Standard primarily with GHS Revision 7, while also addressing issues identified since the implementation of HazCom 2012.

This is intended to improve international regulatory alignment and reduce certain differences with other jurisdictions that use the GHS framework.

Changes to certain hazard classes

The update modifies criteria relating to various hazard classes and categories.

As a result, some products may require a reassessment of their classification and, in certain cases, updates to their labels and Safety Data Sheets.

Improvements to SDS information

HazCom 2024 also introduces adjustments intended to improve the clarity of certain SDS sections and facilitate more precise hazard communication.

Although the 16-section structure remains unchanged, companies will need to check whether the information currently included continues to comply with the new regulations.

Implementation schedule

OSHA has established a transition period to allow manufacturers, importers, distributors and employers to gradually adapt their documentation.

During this period, many organizations will need to review:

• classifications
• labels
• Safety Data Sheets
• internal hazard communication programs
• worker training

For this reason, it is advisable to plan updates to all regulatory documentation in advance.

Common mistakes when adapting an SDS for the United States

Most instances of non-compliance arise from assuming that a European SDS can be used without modification, rather than from errors in the product’s composition.

These are some of the most common mistakes.

1. Assuming REACH is equivalent to OSHA

Although both systems are based on the GHS, their legal obligations differ.

A REACH-compliant SDS must be reviewed before being used in the United States.

2. Failing to review the classification against HazCom

Classification criteria may differ from those of the European system.

The HazCom 2024 update makes this review even more important.

3. Failing to update the SDS when regulations change

Many companies keep the same SDS for years.

However, any significant change to regulations or the product classification may require an update.

4. Using outdated information

One of the most common problems in multinational organizations is maintaining different versions of the same SDS.

Without a centralized system, it is easy to distribute outdated or inconsistent documents.

5. Manually managing hundreds of SDSs

As the number of products and markets grows, manually managing Safety Data Sheets increases the risk of:

• using outdated classifications
• overlooking regulatory updates
• creating inconsistencies between national versions
• distributing incorrect documentation

Checklist: Does your SDS meet OSHA requirements?

Before marketing a chemical product in the United States, it is advisable to review the following aspects.

This checklist provides an initial review, but does not replace a full analysis of the requirements applicable to the product or the specific obligations established by OSHA.

How to keep Safety Data Sheets compliant in the United States

Updating a single SDS can be relatively straightforward.

The real challenge arises when a company markets hundreds or thousands of products in different countries, each with its own regulatory requirements.

Any change to the classification, product composition or regulations may require multiple national versions of the same Safety Data Sheet to be reviewed.

Differences must also be managed in relation to:

• classification criteria
• languages
• labelling requirements
• manufacturer information
• regulatory schedules
• documentation specific to each jurisdiction

In this context, managing SDSs as separate documents or through manual processes significantly increases the risk of errors and makes it harder to maintain regulatory compliance.

Specialized solutions such as ExESS make it possible to centralize regulatory information and generate market-specific versions of Safety Data Sheets from a single source of data.

Among other features, they help to:

• automate SDS generation for different countries
• maintain revision traceability
• update documentation when regulatory requirements change
• manage versions in different languages
• reduce errors arising from manual management

This enables Regulatory Affairs teams to spend less time on repetitive tasks and focus on ensuring regulatory compliance in all markets where the company operates.

Frequently asked questions about SDSs in the United States

Conclusion

The United States has an established system for communicating chemical hazards in the workplace based on the Hazard Communication Standard (29 CFR 1910.1200).

Although these regulations share the principles of the Globally Harmonized System with European legislation, there are sufficient differences to require a Safety Data Sheet prepared in accordance with REACH to be reviewed before it is used in the US market.

The recent HazCom 2024 update further reinforces the need to check that SDSs correctly reflect the classification criteria, the content required by OSHA and the implementation schedule established by the authority.

How can ExESS help?

For companies marketing chemicals in multiple markets, keeping SDSs up to date as regulatory requirements evolve is an operational challenge that requires robust processes, centralized information and ongoing document review.

If your organization manages a large number of Safety Data Sheets for different countries, ExESS can help you centralize regulatory information, automate the generation of market-specific SDSs and facilitate ongoing international regulatory compliance.