Safety Data Sheets (SDSs) should be periodically reviewed and revised as necessary. Every country/ jurisdiction provides guidance on when a safety data sheet should be updated and very few specify a timeline for periodic review. Most jurisdictions are in general agreement that a review or update is necessary as new information becomes available that could impact the accuracy of and protection provided by the SDS.
Guidance is vague on what constitutes new information and what type of information would trigger an update. From a regulatory standpoint, the following changes should automatically trigger SDS review and updates as necessary:
- Composition Change: A change in composition may result in a change in the hazard classification of a product.
- New Hazard Classification: The hazard classification of a substance is subject to change as new data becomes available. Such changes can impact the hazard classification of a product.
- Regulatory List Status: If a substance is added to or removed from certain regulatory lists, the SDS for any product containing that substance should be updated.
- A substance is added to the EU REACH restriction list.
- A substance is added to the US TSCA Section 5 SNUR (Significant New Use Rule) list.
- New Jurisdiction Standard Released/Alignment with Later GHS Revision: A new jurisdictional standard may have additional hazard classes and concentration limits to trigger the classification of a mixture. This may result in a change in hazard classification. Changes to precautionary statements, format, and data requirements are common with the adoption of later GHS revisions.
- Occupational Exposure Limits: New or modified occupational exposure limits or biological exposure indices for a substance should prompt the update of any SDS containing that substance.