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Hazard and compliance regulations can get complicated – fast.

Here’s what we mean: While there is a Globally Harmonized System (GHS), not everyone uses it when authoring SDSs. Some jurisdictions have their own regulations, and others pick and choose aspects from GHS to incorporate into their respective systems.


Below, we’re clearing up some of the more confusing aspects of regulatory jurisdictions and how they apply to SDS authoring so you can ensure your SDSs meet the requirements of the appropriate jurisdiction.

SDS Jurisdictions: The Background

Starting as early as 1992, the United Nations agreed on the fundamental ideas for what would later be known as the Globally Harmonized System of the Classification and Labelling of Chemicals (GHS) in an effort to create a more universal means of labeling and classifying chemicals and streamlining international trade.

While many countries have incorporated aspects of the GHS into their regulations, they are not obligated to adopt all (or even part) of these best practices for their classifications and safety data sheets (SDS).

Instead, all SDSs fall under the jurisdiction of the country where the chemical was manufactured and must meet the particular requirements of their jurisdiction’s regulatory agency. Rules about their creation, labeling, disposal instructions, and more differ from country to country, so it’s imperative to follow the respective jurisdiction’s requirements carefully.

Adding more complexity is the fact that the GHS is revised every 2 years with new revisions. There are currently 8 revisions out there and because jurisdictions have adopted the GHS at different points in time, we currently have situations where some jurisdictions are still on older revisions of the GHS while others are on more recent ones.

Some common jurisdictions include the United States, Canada, and the European Union.

Here in the United States, we rely on the Occupational Safety and Health Administration (OSHA) to assure safe and healthy working conditions by enforcing standards for training, education, outreach, and assistance.

Over in Europe, the EU uses the Registration, Evaluation, Authorization, and Restriction of Chemical Substances (or REACH) to improve the protection of both the environment and human health from chemical risks. They also incorporate the Classification, Labeling, and Packaging regulation (CLP) to align the EU system of classification with GHS.

Canada has a similar system known as the Workplace Hazardous Materials Information System (WHMIS), which incorporates several aspects of GHS to align with Canadian trading partners.

Recommended Reading: GHS, REACH, OSHA Explained

Now let’s see how these jurisdictions play into SDS authoring.

SDS Jurisdiction FAQs

These are some of the most commonly asked questions regarding SDS and their jurisdictions.

If my SDS is in accordance with GHS, do I still need to have one for other jurisdictions/languages?

Yes, even if your SDS meets all standards of a particular revision of the GHS, you will still need to ensure it meets the regulatory requirements for the jurisdiction of the market where it is being sold.

What jurisdiction and language are required?

Most countries have regulations that require the SDS to be authored in the native language or languages of that particular country. For the U.S., that’s English. For Sweden, that’s Swedish. For Canada, that’s both English and French.

Can I use the same SDS for multiple jurisdictions?

In some cases, this may be possible. However, you must approach each situation individually. For example, even though Norway is not part of the EU, they accept an EU-compliant SDS. There are also some countries that have not adopted the GHS formally but allow the use of a GHS compliant SDS written for another jurisdiction. However, while the goal of GHS is to harmonize the global regulatory systems for HazCom, we’re still far from that reality. For that reason, it’s critical to follow the instructions for your respective jurisdiction very closely to stay up-to-date with the requirements.

When/why do I need addresses or emergency contact information for different jurisdictions?

SDS suppliers are typically required to provide emergency contact information in the first section of the SDS. The purpose of this information is to have someone on call who can offer additional information on the hazardous chemical and any appropriate emergency procedures to follow if necessary.

In the EU, most member states can use the contact information for their official emergency response center. In the United States and Canada, most companies use the information of a third-party emergency service provider. Some jurisdictions also have specific requirements like requiring that the emergency contacts be located within the country in question or requiring that the number be manned during the hours that someone might be using the product the SDS is written for.

Streamlined SDS Authoring with TotalSDS

While SDS jurisdiction requirements can be a bit confusing, they don’t have to be. TotalSDS authoring and management software takes the complexity out of SDS authoring. It helps manufacturers and distributors save time and money, meet compliance regulations with ease, disseminate accurate HazCom materials faster, and provide a safer work environment for everyone.

Get in touch to learn more about how TotalSDS can reduce SDS authoring time by up to 80% and help you remain compliant with your jurisdiction.