Common SDS Mistakes I Find in Every Audit

1. Discrepancies Between Section 2 (Hazards Identification) and Section 9 (Physical and Chemical Properties)

This lack of alignment between hazard statements and physical/chemical properties remains one of the most common issues. I estimate it appears in at least 60% of the SDSs I review.

Common errors:

• Flash points in Section 9 indicating flammability without corresponding flammability hazards in Section 2.
• pH values in the corrosive range (≤2 or ≥11.5) lacking corrosivity hazard classifications.
• Vapor pressure values that necessitate inhalation precautions, yet respiratory protection guidance is absent.

A recent example:
During an audit earlier this year, I discovered a solvent-based product with a flash point of 25°C (clearly a flammable liquids Category 2) that had no flammability hazard listed in Section 2. The company explained they had updated the formulation but only revised the physical properties section, neglecting the hazard classification. This oversight could have had severe repercussions.

My tip:
Develop a correlation matrix linking Section 9 properties to expected Section 2 classifications. A simple checklist can catch the vast majority of these inconsistencies. Alternatively, SDS Copilot automatically cross-references physical properties with hazard classifications to prevent these common discrepancies.

2. Incomplete or Overly Generic First Aid Measures (Section 4)

Section 4 should provide precise, product-specific guidance. Instead, I frequently find generic, unhelpful first aid instructions that offer little practical assistance in an emergency.

What I often see:

• Copy-pasted first aid measures that don't address the specific hazards of the ingredients.
• Vague instructions like "seek medical attention if necessary" without specifying when such attention is needed.
• Missing route-specific instructions for products with multiple potential exposure routes (e.g., inhalation, skin contact, ingestion).

An illustrative case:
I recently reviewed an SDS for a product containing phenol – a hazardous chemical requiring specific first aid – that stated only "flush with water". Phenol requires immediate and specialized medical intervention. Such a generalized instruction could lead to improper treatment and adverse outcomes.

Best practice:
Have a medical professional familiar with chemical exposures review your first aid measures. The most effective SDSs include clear triggers for seeking medical help and specific treatments that first responders should know. Modern SDS creation platforms can generate substance-specific first aid measures based on your formulation.

3. Incorrect Hazard Classification Based on GHS Calculation Methods

The Globally Harmonized System (GHS) provides specific mathematical formulas for classifying mixtures. However, companies often guess at classifications or use outdated methods.

Common shortcomings:

• Using simple addition of component percentages instead of the required GHS calculation methods.
• Failing to consider synergistic effects between components in the mixture.
• Not applying the correct cut-off values and concentration limits as specified by GHS.

Example:
A client was consistently underclassifying their products for skin irritation. They were using a calculation that considered components above a certain percentage, missing lower threshold GHS requirements. This resulted in a need to reclassify nearly half their product line.

My strategy:
I employ a tool that precisely applies the GHS algorithms for mixture classification, minimizing guesswork and ensuring compliance. Document each calculation step to demonstrate your due diligence. AI-powered SDS platforms can perform these complex calculations automatically, ensuring accuracy every time.

4. Missing or Imprecise Exposure Controls (Section 8)

Section 8 must provide specific details on exposure limits and protective measures. Often, it's either too generic or completely neglected.

Common deficiencies:

• Listing only OSHA Permissible Exposure Limits (PELs) when other occupational exposure limits (e.g., ACGIH Threshold Limit Values [TLVs], NIOSH Recommended Exposure Limits [RELs]) are more current and protective.
• Recommending personal protective equipment (PPE) that does not adequately address the identified hazards.
• Omitting engineering control recommendations for highly hazardous materials.

Impact:
I recently observed workers handling a corrosive substance with inadequate face protection, despite the SDS only listing basic eye protection. The SDS had failed to include appropriate face shield recommendations. Updating the documentation and implementing better controls immediately improved worker safety.

My advice:
Maintain a database of current occupational exposure limits from various organizations and regulatory bodies. Cross-reference each component against this database to ensure Section 8 reflects the most current and protective measures. This is an area where using an intelligent SDS generation system that maintains up-to-date regulatory data can really make a difference.

5. Overly Vague Incompatibility Information (Section 10)

Section 10 (Stability and Reactivity) should pinpoint specific materials and conditions to avoid. It often contains generic language offering little practical guidance.

Typical issues:

• Broad statements such as "avoid strong acids and bases" without further specifics.
• Missing details about commonly encountered materials that could trigger hazardous reactions.
• A lack of information about conditions (e.g., temperature, pressure, humidity) that can impact stability.

A cautionary tale:
A client experienced a near-miss when a worker stored incompatible materials together – both materials had SDSs, but neither SDS clearly communicated the specific incompatibility. Thorough and specific Section 10 information could have prevented the incident.

Recommendation:
Invest in chemical compatibility testing for new formulations and use precise language in Section 10. Instead of "incompatible with acids," specify: "incompatible with hydrochloric acid and nitric acid; reaction may generate toxic fumes." SDS Copilot draws from an extensive chemical reactivity database to provide specific incompatibility information based on your product's composition.

6. Outdated Regulatory Information (Section 15)

Regulatory requirements are constantly evolving, yet SDSs often contain Section 15 information that hasn't been updated in years.

Common problems:

• References to regulations that have been repealed or amended.
• Failure to include newly regulated substances or reporting requirements.
• Inaccurate or outdated California Proposition 65 listings.

An observation:
A recent audit revealed that a significant percentage of a company's SDSs contained regulatory information that was over a year out of date. In several cases, components had been added to restricted substance lists after the SDS was created, rendering their documents non-compliant.

My suggestion:
Implement a regulatory monitoring system that triggers automatic SDS reviews when relevant regulations change. For smaller companies, conduct a regulatory review of your high-volume products at least twice a year. Alternatively, consider a cloud-based SDS creation platform that continuously updates regulatory information, ensuring your documents remain compliant with minimal effort.

7. Deficient Document Control and Revision Practices

Even the most accurate SDS is problematic if you cannot demonstrate proper document control – something inspectors are increasingly focused on.

Frequently observed errors:

• Missing revision dates or a lack of revision history.
• Absence of a system to ensure that the most current version is readily accessible and in use.
• Inability to demonstrate that updates were made in response to specific new information or regulatory changes.

Important:
During a recent inspection, a company received a citation not because their SDSs were incorrect, but because they could not demonstrate a systematic approach to maintaining their SDSs and keeping them current.

A working solution:
Implement a formal SDS review protocol that includes:

• Scheduled reviews based on the level of risk (higher hazard = more frequent review).
• Triggered reviews whenever formulations are altered, regulations change, or new hazard information becomes available.
• A documented approval process with clearly defined roles and responsibilities.
• A robust distribution system that ensures outdated documents are removed from circulation promptly.

This systematic approach enhances compliance and demonstrates due diligence. Many forward-thinking companies are now using AI-powered SDS management systems that automatically track revisions and maintain a complete audit trail.