For decades, the backbone of chemical safety in most of the American workplaces was the Material Safety Data Sheet (MSDS). If you worked with hazardous chemicals before 2012, you likely remember binders filled with these documents—some short, some long, some clear, and others nearly impossible to decipher. 

In 2012, the Occupational Safety and Health Administration (OSHA) announced a massive shift. They updated the Hazard Communication Standard (HCS) to align with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). 

This transition effectively retired from the MSDS and replaced it with the Safety Data Sheet (SDS). But this was not just a name change; it was a fundamental overhaul designed to solve critical safety flaws inherent in the old system. 

 

The Problem with MSDS: “The Right to Know” 

Under the original 1983 Hazard Communication Standard, OSHA gave workers the “Right to Know” about chemical hazards. However, the standard was performance-based rather than format-based. 

This meant that while chemical manufacturers were required to provide safety information, they had total freedom regarding how to present it. There was no required format, no specified order of information, and no standard terminology. Here are some of the issues with the old MSDS system included: 

  • Inconsistent Formatting: One manufacturer might list “First Aid” at the top, while another buried it on page 4. 
  • Varying Length: Documents range from a single page to extensive technical dossiers. 
  • Confusing Terminology: Different suppliers used different words to describe the same hazards. 
  • Missing Information: Without a strict template, critical safety details were sometimes omitted or overlooked. 

In an emergency, minutes count. A worker splashed with a chemical did not have time to hunt through a dense, unorganized document to find the neutralizing agent. 

 

Enter GHS: “The Right to Understand” 

To fix these inconsistencies, OSHA adopted the GHS, a framework developed by the United Nations. The goal was to standardize how chemical hazards are classified and communicated worldwide. 

Dr. David Michaels, the Assistant Secretary of Labor for OSHA at the time, famously stated that the transition moved workers from having the “Right to Know” to having the “Right to Understand.” 

By adopting GHS, OSHA ensured that a worker in Ohio sees the same hazard warnings, pictograms, and data sheet format as a worker in Germany or Brazil. 

 

Key Changes: MSDS vs. SDS 

The most visible change was the document structure itself. The SDS enforces a strict, standardized layout that every manufacturer must follow. 

Feature  MSDS (Old)  SDS (New/GHS) 
 

Format                      

 

  

No standard format; varied by supplier. 

 

  

Strict 16-section standard format. 

 
 

Focus 

 

  

“Right to Know” (Information access). 

 

  

“Right to Understand” (Comprehensibility). 

 
 

Visuals 

 

  

No requirement for symbols. 

 

  

Mandatory GHS Pictograms. 

 
 

Warnings 

 

  

Inconsistent language. 

 

  

Standardized Signal Words (“Danger” vs “Warning”). 

 
 

Specificity

 

  

Loose hazard definitions. 

 

  

Strict criteria for hazard classification. 

 

 

The Standardized 16-Section Format 

The defining characteristic of the new SDS is its 16-section structure. This specific order ensures that critical emergency information always appears at the beginning of the document. The 16 sections are organized as follows: 

  • Identification: Product name and contact info. 
  • Hazard(s) Identification: Signal words, pictograms, and hazard statements. 
  • Composition/Information on Ingredients: Chemical ingredients and trade secret claims. 
  • First-Aid Measures: Initial care instructions for untrained responders. 
  • Fire-Fighting Measures: Suitable extinguishing equipment and chemical hazards from fire. 
  • Accidental Release Measures: Cleanup, containment, and emergency procedures. 
  • Handling and Storage: Safe handling practices and storage conditions. 
  • Exposure Controls/Personal Protection: Exposure limits (PELs, TLVs) and PPE requirements. 
  • Physical and Chemical Properties: Appearance, odor, pH, flash point, etc. 
  • Stability and Reactivity: Chemical stability and possibility of hazardous reactions. 
  • Toxicological Information: Health effects and routes of exposure. 
  • Ecological Information: Impact on the environment (Non-mandatory for OSHA). 
  • Disposal Considerations: Proper waste disposal methods (Non-mandatory for OSHA). 
  • Transport Information: Shipping and transport guidance (Non-mandatory for OSHA). 
  • Regulatory Information: Safety, health, and environmental regulations (Non-mandatory for OSHA). 
  • Other Information: Date of preparation or last revision. 

Note: While OSHA requires all 16 sections to be present to remain GHS-compliant, they do not enforce sections 12–15, as these fall under the jurisdiction of other agencies like the EPA and DOT. 

 

Visual Communication: Pictograms and Signal Words 

Under the old MSDS system, a label might just say “Caution” or “Toxic” in small print. The GHS transition introduced mandatory visual elements that transcend language barriers. 

 

Signal Words:

There are now only two allowed signal words, which indicate the severity of the hazard: 

  • Danger: Used for more severe hazards. 
  • Warning: Used for less severe hazards. 

 

Hazard Pictograms:

The SDS system utilizes nine distinct pictograms—black symbols on a white background with a red diamond border. These provide immediate visual recognition of risks, such as: 

  • Flame: Flammables. 
  • Skull and Crossbones: Acute Toxicity (fatal or toxic). 
  • Health Hazard: Carcinogens, respiratory sensitizers. 
  • Corrosion: Skin corrosion/burns, eye damage. 

 

Benefits of the Transition:

The shift from MSDS to SDS was costly and time-consuming for manufacturers who had to re-classify every chemical they produced. However, the long-term benefits for safety professionals and employers have been substantial. 

  • Improved Worker Safety
    Standardization reduces confusion. Training employees to read one format is far more effective than teaching them to decipher dozens of different layouts.

 

  • International Trade Facilitation
    Global companies no longer need to produce entirely different safety documents for every country they export to. A GHS-compliant SDS isbroadly accepted across major markets. 

 

  • Cost Savings and Efficiency
    While the initial update was expensive, the standardized system reduces the cost of compliance over time. It simplifies safety training and makes maintaining chemical inventories easier for EHS managers. 

 

  • Better Emergency Response
    First responders (firefighters and EMTs) can now reliably find chemical properties and first aid measures in Sections 4 and 5, without wasting time searching through the document.

 

Conclusion 

The replacement of MSDS with SDS was more than a bureaucratic update; it was a modernization of industrial safety. By moving to the GHS standard, OSHA acknowledged that access to information is useless if that information is not easily understood. Today, the SDS stands as a universal document, ensuring that whether a chemical is manufactured in Texas or Tokyo, the warnings remain clear, consistent, and capable of saving lives.