Safety Data Sheets (SDS) are essential tools for communicating the hazards of chemical substances and mixtures and providing workers and professional users with the information they need to handle, store, transport and use these products safely.

In South Africa, requirements for chemical hazard information are primarily set out under the Occupational Health and Safety Act (OHSA) and the Hazardous Chemical Agents Regulations, 2021.

This framework establishes obligations for manufacturers, importers, suppliers and employers concerning the identification of chemical agent hazards, the information that must be provided to workers and the availability of safety documentation.

South African regulations incorporate the principles of the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) for hazard classification and communication. However, using the GHS as a reference does not mean that an SDS prepared for another jurisdiction can automatically be used in South Africa.

A company marketing chemical products in South Africa must check that the classification, labelling, SDS and other safety information comply with the requirements of the applicable South African legislation.

This is particularly important for international companies that already have SDS prepared under REACH and CLP, OSHA HazCom or other regulatory systems. Although they may share classification concepts and principles, documentation and legal requirements can differ between jurisdictions.

Contents

• Summary
• Which regulations govern SDS in South Africa?
• What are the Hazardous Chemical Agents Regulations, 2021?
• How is the GHS applied in South Africa?
• When is an SDS mandatory in South Africa?
• What information must an SDS in South Africa contain?
• When must an SDS in South Africa be updated?
• What obligations do manufacturers, importers and suppliers have?
• What labelling requirements apply?
• Can a European SDS be used in South Africa?
• Recent regulatory changes
• Common mistakes when preparing an SDS for South Africa
• South Africa SDS compliance checklist
• How to keep SDS compliant in South Africa
• Conclusion
• How can ExESS help?

Summary

In South Africa, obligations relating to Safety Data Sheets are primarily integrated into the framework of the Occupational Health and Safety Act and the Hazardous Chemical Agents Regulations, 2021.

These Regulations set specific requirements for Hazardous Chemical Agents (HCA), including obligations for classification, preparation, review and supply of Safety Data Sheets.

A key first step for a manufacturer or importer is to determine, through a hazard assessment, whether the product is an HCA. If it is, it must be classified according to the GHS and an SDS must be prepared in accordance with the requirements set out in the Regulations.

The Regulations expressly require an HCA SDS to be GHS compliant, classified for the HCA and reviewed at least every five years. It must also be amended when necessary to keep its information accurate and up to date, particularly when new hazard data could change the classification.

Which regulations govern SDS in South Africa?

The main reference is the Occupational Health and Safety Act, 1993, supplemented, with respect to hazardous chemical agents, by the Hazardous Chemical Agents Regulations, 2021.

The Regulations were published in March 2021 and set specific requirements to protect people from risks arising from exposure to hazardous chemical agents in the workplace.

Within this framework, Regulation 14 sets out obligations for manufacturers and importers before supplying a chemical agent to a workplace. These include determining, through a hazard assessment, whether the agent is an HCA and, where applicable, classifying it according to the GHS. The classification must be reviewed if the HCA composition changes.

Regulation 14A specifically sets out the requirements for Safety Data Sheets.

A company marketing chemical products in South Africa must therefore consider the GHS together with:

• whether the product is an HCA
• the prescribed classification criteria
• SDS requirements
• the obligations of manufacturers and importers
• the obligations of suppliers
• the responsibilities of employers

What are Hazardous Chemical Agents?

Hazardous Chemical Agents (HCA) is the term used in South African regulations to determine which chemical agents are subject to these occupational health and safety obligations.

The determination should not be made solely on the basis of the product’s trade name. The manufacturer or importer must conduct a hazard assessment and apply the criteria and cut-off values set out in the Regulations and their annexes.

Where an agent is considered an HCA, the manufacturer or importer must ensure that the relevant GHS classification is carried out.

This step matters because the classification determines the information that must subsequently be communicated through the label and SDS.

What are the Hazardous Chemical Agents Regulations, 2021?

The Hazardous Chemical Agents Regulations, 2021 establish obligations to manage health and safety risks arising from hazardous chemical agents in workplaces.

The Regulations address various aspects of managing these agents, including:

• hazard identification
• classification
• information and training
• labelling
• Safety Data Sheets
• risk assessment
• occupational exposure
• control measures
• monitoring and follow-up

The Regulations are particularly relevant to SDS because they set different obligations for manufacturers and importers, suppliers and employers.

Manufacturer and importer obligations

Before supplying an HCA to a workplace, the manufacturer or importer must conduct the required assessment and, where necessary, ensure that the product is classified according to the GHS.

They must also prepare the SDS in accordance with the prescribed requirements.

The Regulations require an SDS to:

• comply with the GHS
• be classified for the HCA
• be reviewed at least once every five years
• be amended when necessary to ensure its information is accurate and up to date
• include the most recent applicable date, which may be the date of first issue, review or amendment

Supplier obligations

The supplier must provide the SDS when the HCA is first supplied to a workplace and whenever the SDS has been amended.

The Regulations also require the SDS to be provided to anyone in the workplace who requests it.

Document management therefore does not end when the manufacturer creates the SDS. A process must ensure that the relevant recipients receive the updated version.

Employer obligations

The employer must obtain the SDS from the manufacturer, importer or supplier and make it available to people who use, handle or may be exposed to the HCA.

The employer must also provide the information when needed to assess health and safety risks, treat an exposed person or enable an emergency service to respond appropriately.

This makes the SDS a workplace risk management tool, rather than simply a document associated with marketing the product.

How is the GHS applied in South Africa?

The GHS is the basis for classifying HCAs and preparing SDS required by the Regulations.

However, it is important to distinguish between using the GHS as a classification system and automatically applying another country’s legislation just because it also uses the GHS.

South African regulations require HCAs to be classified according to the GHS and SDS to be GHS compliant.

A company that already has an SDS for the European Union, United States or Australia may use its data as a starting point, but must verify that the classification and document meet South African requirements specifically.

Classification before preparing the SDS

The regulatory process can be summarised as follows:

Product assessment → Determine whether it is an HCA → GHS classification → SDS and labelling → Supply and maintenance of information

Classification should not be carried out after the SDS has been generated. It determines much of the information that must appear in the SDS.

In addition, the Regulations require the classification to be reviewed when the HCA composition changes.

This may also trigger a review of the SDS and label.

The GHS does not remove national obligations

South Africa’s use of the GHS supports international harmonisation, but it does not mean that an SDS prepared under another GHS-based system is automatically valid.

For example, a company may have an SDS compliant with European CLP, but it must check it before using it in South Africa.

The underlying data may be shared; the regulatory requirements determining the final document may differ.

When is an SDS mandatory in South Africa?

The specific obligation to prepare an SDS under the Hazardous Chemical Agents Regulations is linked to HCAs.

Where a product falls into this category, the manufacturer or importer must prepare an SDS in accordance with Regulation 14A.

The Regulations also specify when the document must be supplied.

The manufacturer or importer must provide the SDS to the HCA supplier and to people who may be affected. The supplier must provide it when the product is first supplied to a workplace, when the SDS is amended and when someone in the workplace requests it.

The employer must obtain the SDS and make it available to people who use, handle or may be exposed to the HCA.

The obligation should therefore be understood as an ongoing process for communicating information, not simply creating a document when the product is marketed.

What information must an SDS in South Africa contain?

The Hazardous Chemical Agents Regulations, 2021 require an SDS to be GHS compliant and to follow the structure prescribed by the Regulations.

The information must make it possible to identify the product, understand its hazards and determine the measures needed for safe handling, storage and use.

Companies must therefore build SDS from current technical and regulatory information, rather than simply adapting a document used in another market.

The main information categories include:

• product and supplier identification
• hazards identification
• composition/information on ingredients
• first-aid measures
• firefighting measures
• accidental release measures
• handling and storage
• exposure controls and personal protection
• physical and chemical properties
• stability and reactivity
• toxicological information
• ecological information
• disposal considerations
• transport information
• regulatory information
• other relevant information

This structure organises information consistently with the GHS and makes it easier for workers, safety managers, healthcare professionals and emergency services to use.

Product identification

The first part of the SDS must clearly identify the chemical product.

The information must be consistent with the label and with the information used by the manufacturer or importer.

It may include:

• trade name
• product identifier
• chemical name
• identified uses
• restrictions on use
• manufacturer or supplier information
• contact details
• emergency telephone number, where applicable

Centralised management of these data is especially useful when a company markets the same product in different countries.

Hazards identification

The hazards section must reflect the classification carried out under the applicable South African system.

The following must be consistent:

classification → pictograms → signal word → hazard statements → precautionary statements → SDS

Discrepancies between these elements can cause regulatory and operational problems.

For example, if a change in composition causes a mixture to be classified for a particular health hazard, changing only the label is not enough. The impact on the SDS must also be assessed.

Composition/information on ingredients

The SDS must provide enough information about the composition for the hazards associated with the product to be understood.

For mixtures, this means identifying relevant ingredients and communicating the necessary information under the applicable criteria.

Managing this information is particularly important for companies with many formulations, since the same ingredient may appear in multiple products.

A change in the concentration of an ingredient may affect the:

• mixture classification
• labelling
• SDS
• exposure information
• protective measures

When must an SDS in South Africa be updated?

Companies must understand that an SDS is not a permanent document.

The Hazardous Chemical Agents Regulations, 2021 require an SDS to be reviewed at least every five years.

However, the five-year period should not be interpreted as permission to leave the document unchanged during that time.

The Regulations require the SDS to be amended when necessary to ensure its information is accurate and up to date.

This is especially important when new information about product hazards becomes available and could change the classification.

What changes can trigger a review?

Events that should trigger an assessment include:

• changes in composition
• changes in the concentrations of hazardous ingredients
• new toxicological information
• new ecotoxicological information
• changes to relevant physical or chemical properties
• new hazard information
• changes in classification
• changes in labelling
• regulatory changes
• changes to transport information
• changes to manufacturer or supplier details

Not every change necessarily requires a new SDS version, but each should trigger an impact assessment.

Revision date

Version management should make it possible to identify when the SDS was prepared, reviewed or amended.

This helps demonstrate that the company has current information and prevents outdated versions from continuing to be used after a relevant change.

For an organisation with hundreds or thousands of products, tracking these dates manually can be difficult.

A system should therefore make it possible to identify automatically:

• creation date
• review date
• document version
• reason for the change
• affected products
• documents that need to be regenerated

What obligations do manufacturers, importers and suppliers have?

South African regulations establish different responsibilities across the supply chain.

Manufacturers and importers

Manufacturers and importers have a key responsibility because they must determine the product’s hazards and prepare the necessary information before supplying it.

Relevant obligations include:

• conducting a hazard assessment
• determining whether the product is an HCA
• classifying it according to the GHS where applicable
• preparing the SDS
• keeping information up to date
• reviewing the classification when the composition changes
• providing documentation to the relevant recipients

The manufacturer or importer must therefore have reliable information about the product’s composition and properties.

Suppliers

The supplier plays an important role in passing information on to workplaces.

The supplier must provide the SDS when the HCA is first supplied and when the SDS has been amended.

The supplier must also provide it when requested by someone in the workplace.

A reliable mechanism is therefore needed to ensure that the version distributed is current.

Employers

The employer must obtain the relevant SDS and ensure it is available to people who use, handle or may be exposed to the HCA.

SDS information must form part of workplace chemical risk management.

For example, an SDS can be used to:

• assess risks
• establish control measures
• select personal protective equipment
• train workers
• respond to spills
• respond to fires
• provide information to medical or emergency services

The SDS should not simply be stored as a document. It must be accessible to the people who need to use its information.

What labelling requirements apply?

Labelling and the SDS are part of the same hazard communication system.

The product classification determines which communication elements must be used, and the label information must be consistent with the SDS.

Relevant elements may include:

• product identifier
• hazard pictograms
• signal word
• hazard statements
• precautionary statements
• supplier information

The company should avoid managing the label and SDS as separate documents.

For example, if the classification of a mixture changes, the impact should be assessed at the same time on:

classification → label → SDS → safety information → related documentation

This approach is particularly important when SDS are generated automatically from a regulatory database.

Can a European SDS be used in South Africa?

An SDS prepared under REACH and CLP may contain much of the technical data needed to prepare an SDS for South Africa.

However, it should not be used directly without a specific review.

The fact that both South Africa and the European Union use the GHS as the basis of their hazard communication systems does not mean that their regulatory frameworks are identical.

Before using a European SDS in South Africa, the company should check, among other things:

• classification under the South African framework
• composition
• applicable cut-off and concentration limits
• labelling elements
• regulatory information
• supplier details
• specific SDS requirements
• review date and status

Practical example

A European company markets a mixture in South Africa and has an SDS compliant with CLP.

The company could use the following as a starting point:

• composition
• physical and chemical properties
• toxicological data
• ecotoxicological data
• transport information
• first-aid measures
• firefighting measures

Before distributing the SDS in South Africa, the company should recheck the classification and hazard communication elements against South African requirements.

If the classification changes, the affected SDS sections and the label must also be reviewed.

The difference may seem small from a documentation perspective, but it becomes very important when a company manages hundreds of products across different jurisdictions.

Recent regulatory changes

The Hazardous Chemical Agents Regulations, 2021 significantly updated obligations relating to hazardous chemical agents in the workplace and replaced the previous 1995 framework.

One important change was the introduction of a GHS-based approach to classifying and communicating the hazards of chemical agents.

For companies already marketing products in South Africa, this meant reviewing the classification, labelling and SDS of affected products.

The transition to the 2021 framework also reinforced the need to have current product hazard information and maintain SDS in accordance with the requirements of the Regulations.

SDS review

The Regulations require SDS to be reviewed at least every five years, but they must also be updated when necessary to ensure the information is accurate and up to date.

This is particularly important when new hazard data on a substance or mixture could change its classification.

Companies should therefore not treat the five-year period as a fixed document update interval. They need mechanisms to detect changes requiring review sooner.

Classification changes

The classification must be reviewed when the composition of an HCA changes.

For example, if the concentration of a hazardous ingredient in a mixture changes, the company must assess whether this affects the product classification.

If the classification changes, the consequences must also be assessed for:

• the label
• the SDS
• hazard communication elements
• protective measures
• information provided to workers

This link between composition and documentation is one of the main reasons manual SDS management can lead to errors.

Common mistakes when preparing an SDS for South Africa

1. Using a European SDS directly

An SDS’s compliance with REACH and CLP does not mean it can automatically be used in South Africa.

The classification and documentation must be reviewed against South African requirements.

2. Simply translating an SDS

Translation alone does not make an SDS compliant.

The company must also check:

• classification
• labelling
• regulatory information
• supplier
• composition
• specific SDS requirements

3. Confusing the GHS with South African legislation

The GHS provides the basis for hazard classification and communication, but a company’s obligations arise from South African legislation.

Simply describing an SDS as “GHS compliant” should not be the only criterion used to check compliance.

4. Failing to review an SDS when the composition changes

A formulation change may alter a mixture’s classification.

If the company updates only its internal formula and does not assess the impact on SDS and labels, it may distribute documentation that no longer matches the product.

5. Waiting five years to update an SDS

The five-year period is a review requirement, not a guarantee that the SDS can remain unchanged throughout that time.

If relevant new information becomes available, the SDS must be assessed and updated where necessary.

6. Managing SDS and labels separately

The classification must be consistent across all hazard communication documentation.

A change that affects the classification should trigger a simultaneous assessment of the SDS and labelling.

7. Failing to track distributed versions

When an SDS is amended, the supplier must provide the updated version in accordance with the obligations set out in the Regulations.

It is therefore important to identify the current version and prevent outdated versions from continuing to circulate.

South Africa SDS compliance checklist

How to keep SDS compliant in South Africa

The main challenge arises when a company moves from managing a few SDS to handling hundreds or thousands of products.

In that situation, manually reviewing each document can quickly become difficult to control.

A change to one substance may affect many mixtures. A new classification may require several documents to be reviewed. An international company may also need different versions of the same product for South Africa, the European Union, the United States and other markets.

Centralising product data

A more effective way to manage this process is to maintain a central source of information on:

• substances
• composition
• classification
• properties
• hazards
• toxicological information
• ecotoxicological information
• labelling
• regulatory requirements
• manufacturers
• suppliers
• translations
• SDS versions

The SDS then becomes an output of the technical and regulatory data stored in the system, rather than a standalone document that must be manually edited every time.

Automating impact assessment

When information about a substance changes, the company should be able to determine which products may be affected.

For example:

Change to a substance → classification review → identify affected mixtures → review SDS and labels → generate new versions

This process is particularly important for companies with large product portfolios.

Tracking the five-year review

South African requirements make it necessary to track SDS review dates.

A management system can help identify:

• SDS approaching their review date
• SDS that are already due for review
• recently amended documents
• products affected by regulatory changes
• currently valid versions

This means compliance no longer depends entirely on manual reminders and spreadsheets.

Managing South Africa alongside other markets

International companies often work from a single source of product information and generate market-specific documentation.

This approach allows shared technical data to be reused without assuming that regulatory requirements are identical.

For example, the same composition and property information may be used to generate documentation for:

• South Africa
• the European Union
• the United States
• Australia
• New Zealand
• other international markets

The benefit is to centralise the data and tailor the output to each jurisdiction, instead of maintaining entirely separate documents.

Frequently asked questions about SDS in South Africa

Conclusion

Safety Data Sheets in South Africa must be managed within the framework established by the Hazardous Chemical Agents Regulations, 2021 and the Occupational Health and Safety Act.

The South African system uses the GHS as the basis for hazard classification and communication, but companies must follow the specific requirements established by national legislation.

For manufacturers and importers, the process begins by assessing the product and determining whether it is a Hazardous Chemical Agent. Where required, it must be classified according to the GHS and an SDS that meets the requirements of the Regulations must be prepared.

Management does not end when the document is first prepared. SDS must be reviewed at least every five years and updated when relevant new information becomes available or product changes may affect the classification or safety information.

For companies with large product portfolios, managing these processes manually can be difficult. Changes to composition, classification or regulatory information may affect many SDS and labels at the same time.

A central source of information on substances, products and regulatory requirements makes it easier to control versions, identify documents affected by changes and keep documentation consistent.

How can ExESS help?

Managing Safety Data Sheets for South Africa involves much more than generating a GHS-compliant document.

Companies must track product composition, assess classification changes, keep SDS up to date and ensure that distributed documentation is the current version.

The challenge increases when the same products are marketed in other countries: one substance may be used in many formulations, and each jurisdiction may require specific documentation.

ExESS centralises the data needed to generate and manage Safety Data Sheets for different markets.

With a centralised information source, companies can:

• manage substance and product data in a single system
• apply jurisdiction-specific regulatory requirements
• generate SDS tailored to the South African market
• manage different languages and versions
• track review dates
• identify products affected by changes to substances or classifications
• keep the information used in SDS consistent
• reduce manual work involved in document updates

For organisations marketing chemical products in South Africa and other international markets, this approach makes it possible to reuse shared technical data without assuming that regulatory requirements are identical in every jurisdiction.

Would you like to see how ExESS can help manage your SDS and regulatory requirements? Request a demo.