Top 5 Safety Data Sheet Omissions | RMT

Safety Data Sheets (SDSs) are critical documents providing your first line of defence when it comes to chemical safety.

Every hazardous chemical product or substance has a manufacturer-supplied SDS that details the composition, properties and safety information for the chemical. SDSs are key sources of information for communicating hazards and handling procedures to assist regulatory compliance, worker safety, environmental safety and emergency response.

However, despite an internationally standardised 16-section format, many SDSs are missing critical data points that could significantly impact safety and compliance.

You should review your SDS library for the following potential data gaps:

1. SDS Section 2: Misalignment between hazard classifications and section 9 properties

Section 2 of an SDS identifies and classifies hazards associated with the chemical and lists the essential elements for labelling. SDS Section 9 lists the physical and chemical properties of the chemical.

Misalignment between the two sections can occur when property values in section 9 do not have a corresponding hazard listed in Section 2. For example, flash point properties indicating flammability not having a flammability hazard, or a chemical may list corrosive pH values but not record a corrosivity hazard classification.

Review your SDS to check correlation between Section 9 properties to expected Section 2 classifications. Chemical management software may automatically apply rules based upon Global Harmonised System (GHS) mathematical formulas to list Hazard Classifications and avoid discrepancies with the product’s properties.

2. SDS Section 4: Incomplete or Generic First Aid Measures

Section 4 of an SDS provides first aid instructions for exposure to hazardous substances, detailing immediate actions to take in case of an incident. Generic or vague instructions such as "seek medical attention if necessary" or “flush with water” provide little practical assistance in an emergency. Also, products with multiple potential exposure routes (such as inhalation, skin contact or ingestion) may lack route-specific instructions.

Effective SDSs include clear triggers for seeking medical help and specific treatments that first responders should know. Chemical management systems can provide detailed first aid measures across all exposure routes.

3. SDS Section 7: Clear real-world handling instructions

The handling and storage information in Section 7 of an SDS sometimes provides inadequate detail in instructions, such as “Avoid contact with skin” or “Use adequate ventilation”. Such statements are too generic to be actionable, leading to inconsistent practices and avoidable incidents.

Chemical workers need clear, specific knowledge of how the product should be stored or transferred such as keeping containers tightly closed, the need for well-ventilated storage areas, or protection from heat or sunlight. Incompatible materials should be referenced and consistent with information in SDS section 10. Chemical management software may include detailed handling information and precautions for every chemical in their database.

4. SDS Section 8: PPE Recommendations based on risk scenarios

Section 8 provides Exposure Controls and Personal Protection recommendations based on the ingredients and potential uses of the product. However, this information might simply say “use gloves” or “wear eye protection” without specifying the material type or application standards. Not all gloves, respirators, or goggles offer the same level of protection. For example, latex gloves may not protect against prolonged exposure to solvents, and certain respirators may be ineffective against filtering vapours or particulates. PPE must be chosen on chemical compatibility and potential exposure routes.

Where applicable, high quality SDSs will specify glove material (e.g., nitrile or neoprene), respirator types (such as N95, P100, full-face with organic vapour cartridge), eye protection (e.g., ANSI-rated goggles or face shields).

It is important to conduct a risk assessment using the product SDS information to determine the full PPE required for your specific uses and working environment. Chemical management software can automatically list manufacturer default PPE or provide editable lists for additional PPE for inclusion in your product documentation.

5. SDS Section 8: Specific Exposure Limits for All Ingredients

Some SDSs may list general Occupational Exposure Limits (OELs) for major ingredients only, ignoring those below 1% or 0.1% thresholds. Even at low levels, some substances can cause allergic reactions, long term health effects, or contribute to chemical incompatibilities. Trace components can pose serious health risks, especially if carcinogenic, reproductive toxins, respiratory sensitisers, or endocrine disruptors.

Without complete OEL data for all known toxic components even at low concentrations, conducting thorough risk assessments or designing effective PPE protocols is impossible. Chemical management software can provide full and up to date ingredient listings, including hazardous components with relative percentage compositions below threshold limits.

6. SDS Section 8: Proprietary mixtures

Another data gap may occur when manufacturers claim key ingredients are legally protected proprietary “trade secrets” and provide no CAS numbers or hazard data.

Trade-secret claims should not come at the expense of safety. Ambiguity makes hazard communication ineffective. Workers, safety officers, and emergency personnel can’t protect themselves from what they don’t know exists.

Where ambiguity on chemical ingredients exists, contact the manufacturer for disclosure of proprietary information such as chemical family or functional group, and hazard classifications to improve your safety documentation.

7. SDS Section 10: Specific decomposition products

The stability and reactivity information in Section 10 may only mention that the product may decompose when heated, without specifying the decomposition products (the substances formed when a compound breaks down into simpler components).

Generic phrases like “Hazardous decomposition products may include carbon monoxide” may be used that do not give the full picture.

In a fire, spill or high temperature scenario, chemicals can break down into highly toxic gases like hydrogen cyanide, phosgene, or sulfur oxides. Emergency responders rely on this important information to prepare effective response strategies for worst-case scenarios and to protect lives.

This information may be mentioned under Section 5, but high quality SDSs more usefully list it in both sections. Chemical management software can help identify specific and known hazardous decomposition products for a chemical under thermal stress, heat, fire, combustion, or incompatible conditions.

8. SDS Section 10: Vague incompatibility Information

Section 10 (Stability and Reactivity) should pinpoint specific materials and conditions that should be avoided when storing or transporting different products. However, generic information offering little practical guidance may be used: Broad statements such as "avoid strong acids and bases" without specifics, not including common substances that could trigger hazardous reactions, or conditions that can impact stability (e.g., temperature, pressure, humidity).

SDS documentation should be updated with precise language, such as "Reacts violently with alkalis. Reacts exothermically on dilution with water. Reacts with chlorine products and oxidising agents liberating toxic chlorine gas". Chemical compatibility testing for new formulations can be conducted. Chemical management software may implement storage incompatibility checks to automatically warn of proximity risks based upon your product's composition.

9. SDS Sections 12-15: Environmental fate and transport info

Sections 12 to 15 of an SDS cover ecological, transport, regulatory and disposal information. Depending on region, some of these data points may not be enforced. Suppliers may leave environmental data like ecotoxicity, persistence, or mobility in soil and water incomplete or omitted entirely.

Such information is crucial for safe disposal and spill response planning, especially for chemicals used in large volumes or near sensitive areas like drains or soils. Environmental risk assessments may fall short if data on biodegradability, bioaccumulation potential or aquatic toxicity are not available. This makes it harder to comply with environmental regulations or local wastewater discharge limits.

Omission of such information can lead to regulatory violations or environmental harm. Chemical management software may supplement environmental data with ecological impact information and provide search and reporting facilities based on specific regulations.

10. SDS Section 15: Outdated regulatory information

In Section 15, the manufacturer provides international and national regulatory advice applying to the product not provided elsewhere in the SDS. However, regulatory requirements evolve and older SDSs may contain Section 15 information that hasn't been updated for repealed or amended regulations, new substances or reporting requirements, or outdated listings for regulations such as California Proposition 65. This may render the product documentation non-compliant.

SDS reviews should be regularly scheduled or automatically triggered when relevant regulations change. Chemical management systems may continuously update regulatory information and automate SDS expiry notices to ensure documentation remains compliant with minimal effort.

Conclusion

Missing or minimal information in SDSs creates blind spots and increase risk in your chemical management strategy, from worker safety to environmental compliance:

Delaying spill or emergency responses
Improper PPE use and selection
Hindering training and safety audits
Increasing regulatory liability

Don’t rely on “good enough” chemical safety data to protect your workers, community and reputation. Where data is missing, reach out to suppliers for updated or expanded SDSs, or consider a chemical management system that reviews and standardises SDS content and alerts for incomplete or outdated SDSs.

Contact RMT Global to learn how ChemAlert implements a smarter, safer chemical management system.