Key takeaways

• Fewer than 1% of the approximately 85,000 commercial chemicals have undergone comprehensive safety evaluation.
• Traditional chemical testing is expensive, time-consuming, and heavily dependent on animal studies.
• New Approach Methods (NAMs) use computational models and biological data to predict chemical hazards more efficiently.
• Regulatory frameworks such as TSCA, REACH, OSHA HazCom, and GHS increasingly recognize data generated through NAMs.
• Modern SDS management requires continuous monitoring of regulatory updates, supplier revisions, and new toxicological evidence rather than relying on periodic reviews alone.

Why is chemical hazard testing fundamentally broken—and what's changing? 

Testing for chemical hazards is a cornerstone of occupational safety, GHS classifications, and Safety Data Sheets (SDSs). But the existing testing system is under increasing pressure as it is sluggish, expensive, and unable to cope with dozens of chemicals in use in commerce today. Regulators are taking up New Approach Methods (NAMs) and other predictive technologies, and the identification and communication of chemical dangers is changing quickly. It is important for EHS professionals to understand these developments to keep SDSs accurate, remain compliant, and ensure worker safety. In this paper, we look into why the present testing paradigm is being reconsidered and what it means for the future of chemical hazard management. 

What makes traditional chemical hazard testing challenging?

Traditional toxicology has provided the scientific basis for chemical regulations for decades. While these methods remain important, they present several significant limitations.

1. Limited Safety Data

Many chemicals entered commercial use long before modern safety standards existed. Consequently, toxicological information for thousands of substances remains incomplete, making hazard classification more difficult for manufacturers and regulatory agencies.

2. Long Testing Timelines

Comprehensive toxicological studies often require months or even years to complete. As new chemicals continue entering the market, conventional testing cannot evaluate them quickly enough.

3. High Costs

Animal studies and long-term toxicity research require substantial financial investment. The cost of testing large chemical inventories can discourage comprehensive hazard evaluations.

4. Ethical Concerns

Governments, industries, and researchers are actively seeking alternatives to animal testing. Ethical considerations have become one of the major drivers behind the development of modern hazard assessment methods.

5. Rapid Chemical Innovation

Chemical innovation now advances faster than traditional testing can support. New formulations, ingredient substitutions, and product improvements are introduced continuously, while toxicological research often lags behind.

How chemical hazard testing currently works 

Any organization that handles a chemical does a formal hazard assessment. It happens before you use that substance. This hazard assessment is based on the premise of identifying the potential dangers to human health and the environment. This method is usually made up of: 

1. Chemical development: 

The physical and chemical properties of the chemical are characterized and documented by chemical development scientists.  

2. Hazard testing: 

The substance is screened for hazards including acute toxicity, skin and eye irritation, carcinogenicity, reproductive toxicity, and environmental impacts. 

3. Hazard classification: 

Test outcomes are taken into account to determine hazard classification and labeling in compliance with laws such as GHS, TSCA, and REACH. 

4. SDS authoring: 

The Safety Data Sheet presents hazard information, in particular Section 11 (Toxicological Information) and Section 12 (Ecological Information). Most of the testing is done according to OECD Test Guidelines, providing internationally accepted and repeatable results. But often, danger classification is self-declared by manufacturers based on the available evidence, rather than independently validated by authorities. As a result, various suppliers may label the same chemical differently, which makes it necessary for EHS teams to rigorously analyze supplier SDSs and keep hazard information correct and up to date. 

Why Are Supplier SDSs Not Always Enough?

Many organizations assume that receiving an SDS from a supplier guarantees accurate and current hazard information. In reality, this assumption can create compliance risks.

Most hazard classifications are self-declared by manufacturers using available scientific evidence rather than independently verified by regulatory agencies. As new research becomes available, different suppliers may classify the same substance differently.

Supplier SDSs can also become outdated because:

• New toxicological studies are published.
• Regulatory agencies revise hazard classifications.
• Chemical formulations change.
• Exposure limits are updated.
• New scientific evidence identifies previously unknown hazards.

For EHS professionals, relying solely on supplier documentation without periodic review can result in outdated hazard communication and increased compliance risk.

What is the green chemistry testing gap?

One of the biggest challenges in modern chemical management is ensuring that replacement chemicals are genuinely safer than the substances they replace.

This issue is commonly known as the green chemistry testing gap.

As hazardous substances are restricted or phased out, manufacturers often introduce alternative ingredients. However, these replacement chemicals may reach the market before comprehensive toxicological testing has been completed.

This creates the risk of regrettable substitution—replacing one hazardous chemical with another that later proves to have similar or even greater health or environmental risks.

Researchers, including green chemistry pioneers John Warner and James Ludwig, have argued that safety evaluation should occur during chemical design rather than after commercialization. Their work supports a preventive approach in which hazard reduction becomes an integral part of product development instead of relying solely on downstream regulatory controls.

What are new approach methods (NAMs)?

New Approach Methods (NAMs) are modern scientific techniques used to evaluate chemical hazards with little or no reliance on animal testing. Rather than depending exclusively on traditional laboratory studies, NAMs combine computational models, cell-based research, biological data, and advanced analytics to predict how chemicals may affect human health and the environment.

Regulatory agencies such as the U.S. EPA and the European Chemicals Agency (ECHA) increasingly use NAM-generated evidence to strengthen chemical risk assessments, prioritize substances for further evaluation, and address the growing backlog of chemicals lacking comprehensive toxicological data.

While NAMs do not completely replace conventional testing for every regulatory endpoint, they have become an essential component of modern chemical safety assessment.

What types of new approach methods are used?

Quantitative Structure-Activity Relationship (QSAR) Models

QSAR (Quantitative Structure-Activity Relationship) models predict the potential hazards of a chemical by analyzing its molecular structure and comparing it with substances that have already been studied.

These models can estimate the following:

• Acute toxicity
• Skin and eye irritation
• Skin sensitization
• Environmental toxicity
• Potential carcinogenicity
• Bioaccumulation potential

Because QSAR models require only molecular structure data, they can rapidly screen thousands of chemicals before laboratory testing begins. This makes them particularly valuable for identifying substances that may require additional investigation.

Read-across approaches

Read-across predicts the hazards of a chemical by using toxicological information from structurally similar substances.

Instead of repeating costly and time-consuming experiments, scientists evaluate chemicals that share similar physical, chemical, or biological properties to estimate missing hazard information.

Read-across is commonly used to:

• Fill toxicological data gaps
• Reduce duplicate animal studies
• Support REACH registration requirements
• Improve hazard assessments where limited testing data exists

Although read-across requires strong scientific justification, it has become an accepted tool for many regulatory submissions.

High-throughput screening (HTS)

High-throughput screening (HTS) evaluates thousands of chemicals rapidly by measuring how they interact with biological systems at the cellular or molecular level.

Rather than waiting years for traditional toxicology studies, HTS can identify chemicals that may affect critical biological pathways within days or weeks.

HTS helps researchers detect:

• Cellular responses
• Receptor interactions
• Changes in molecular pathways
• Early indicators of toxicity

These findings help regulators prioritize chemicals that require more detailed investigation while accelerating the overall hazard assessment process.

How Are Regulatory Agencies Adopting NAMs?

The growing acceptance of NAMs reflects the need to evaluate chemicals more efficiently while maintaining scientific rigor.

U.S. EPA

The U.S. Environmental Protection Agency increasingly incorporates computational toxicology, QSAR predictions, and bioactivity data into chemical risk evaluations under the Toxic Substances Control Act (TSCA).

One of its most valuable public resources is the CompTox Chemicals Dashboard, which provides extensive information on thousands of chemicals, including:

• Chemical structures
• Regulatory status
• Toxicity predictions
• Exposure information
• Bioactivity data
• Existing hazard studies

For EHS professionals, CompTox offers an additional layer of scientific evidence that can support supplier SDS reviews, chemical substitution projects, and internal risk assessments.

European Union (REACH)

The European Union’s REACH Regulation has been a major driver of alternative testing strategies.

REACH increasingly accepts the following:

• QSAR predictions
• Read-across justifications
• Weight-of-evidence assessments
• Integrated testing strategies

These approaches help reduce unnecessary animal testing while allowing companies to meet regulatory information requirements through scientifically validated alternative methods.

OSHA and Hazard Communication

Although OSHA’s Hazard Communication Standard primarily governs workplace hazard communication rather than chemical testing itself, updates to the HazCom Standard increasingly reflect evolving scientific evidence and changes to GHS classification criteria.

As hazard classifications evolve, employers must ensure that SDSs, labels, employee training, and workplace chemical inventories remain current.

Traditional Testing vs. New Approach Methods

Rather than replacing traditional toxicology entirely, NAMs complement existing testing by helping regulators and manufacturers identify potential risks earlier and more efficiently.

What does this mean for SDS management?

As scientific understanding evolves, SDS management can no longer be treated as a periodic administrative task. Instead, it should function as a continuous compliance process.

Organizations should regularly review Safety Data Sheets when

• New toxicological studies become available.
• Regulatory agencies revise hazard classifications.
• Suppliers update formulations.
• Exposure limits change.
• Ingredient substitutions occur.
• New approach methods generate additional hazard information.

EHS professionals should also compare supplier SDSs for inconsistencies, verify revision dates, and ensure that workplace chemical inventories reflect the latest available hazard information.

Modern SDS management platforms can simplify this process by centralizing SDS libraries, tracking supplier revisions, monitoring regulatory updates, and helping organizations maintain compliance across multiple jurisdictions.

Frequently Asked Questions

1. Why is traditional chemical hazard testing considered inadequate?

Traditional testing is often too slow, expensive, and resource-intensive to evaluate the growing number of chemicals used worldwide. Many commercial substances still lack complete toxicological data, creating uncertainty in hazard classification and workplace risk assessments.

2. Do new approach methods replace animal testing?

No. NAMs currently complement rather than completely replace traditional testing. Regulatory agencies use them alongside conventional studies to strengthen hazard assessments and reduce unnecessary animal testing where scientifically appropriate.

3. Can safety data sheets become outdated?

Yes. SDSs may become outdated when new toxicological studies, revised hazard classifications, ingredient substitutions, or regulatory updates are published. Organizations should review SDSs continuously rather than relying solely on scheduled updates.

4. Why do different suppliers classify the same chemical differently?

Many hazard classifications are self-declared based on available scientific evidence. Differences in data interpretation, testing methods, or newly available research can result in varying classifications between suppliers.

5. How can EHS teams improve SDS compliance?

Organizations should maintain an up-to-date chemical inventory, review supplier SDSs regularly, monitor regulatory changes, verify hazard classifications, and use SDS management software to automate document updates and compliance tracking.

Conclusion

Chemical hazard testing is entering a new era. While traditional toxicology remains essential, it can no longer keep pace with the rapid growth of commercial chemicals and evolving scientific knowledge. New Approach Methods—including QSAR models, read-across, and high-throughput screening—are enabling regulators to evaluate chemical hazards more efficiently while reducing reliance on animal testing.

For EHS professionals, this shift means that SDS management must become a continuous process rather than an annual compliance exercise. Staying informed about regulatory updates, supplier revisions, ingredient substitutions, and emerging toxicological evidence is critical to maintaining accurate Safety Data Sheets and protecting workers.

CloudSDS helps organizations simplify this process by centralizing SDS management, monitoring supplier updates, tracking regulatory changes, and maintaining an accurate chemical inventory. By combining automated compliance tools with continuously updated hazard information, organizations can strengthen workplace safety while keeping pace with the future of chemical hazard assessment.