The Globally Harmonized System (GHS) continues to evolve as regulatory bodies worldwide refine chemical safety standards to reflect emerging scientific data and real-world workplace incidents. Since the UN published the first GHS edition in 2003, the system has been updated every two years to ensure chemicals are classified, labeled, and documented with precision and consistency. GHS Revision 7, adopted internationally, and the subsequent revisions including Revision 10 and 11 (published in 2023 and 2025 respectively), have introduced significant changes to Safety Data Sheet (SDS) requirements that directly impact employers, chemical suppliers, manufacturers, and EHS teams globally. 

The updated SDS format maintains the fundamental 16-section structure but introduces stricter content requirements, enhanced hazard classifications, and more precise information standards. OSHA’s 2024 final rule, effective July 19, 2024, aligns U.S. regulations with GHS Revision 7, demanding compliance from all chemical manufacturers, importers, distributors, and employers handling hazardous substances. Industry estimates suggest that these changes will require revision of approximately 95 percent of existing SDSs and 64 percent of shipped container labels. 

What Are the Latest Changes to GHS SDS Format Requirements? 

Part 1: Background 

What Is the GHS SDS Format? 

The GHS SDS consists of 16 mandatory sections presenting chemical hazard information in a standardized, globally recognized format. This uniform structure ensures consistency across international borders, facilitating safer chemical management throughout supply chains. 

The 16-section structure includes: 

• Identification 

• Hazard identification 

• Composition/information on ingredients 

• First-aid measures 

• Fire-fighting measures 

• Accidental release measures 

• Handling and storage 

• Exposure controls/personal protection 

• Physical and chemical properties 

• Stability and reactivity 

• Toxicological information 

• Ecological information 

• Disposal considerations 

• Transport information 

• Regulatory information 

• Other information 

Global adoption rates vary by region. The European Union enforces GHS through the Classification, Labelling and Packaging (CLP) Regulation, Canada implements it via WHMIS regulations, Australia completed its transition to GHS Revision 7 in January 2023, and the United States follows OSHA’s Hazard Communication Standard (HCS). This regional variation necessitates market-specific SDS customization despite the globally standardized format. 

Why GHS Updated Its SDS Requirements 

The evolution of GHS standards reflects several critical drivers. Scientific understanding of chemical hazards has advanced significantly, revealing previously unrecognized health effects and environmental impacts. Data on respiratory hazards, skin sensitization mechanisms, and chronic toxicity classifications has improved dramatically, rendering older classification systems incomplete and potentially dangerous. 

Cross-country inconsistencies in chemical classification created substantial trade barriers and confusion for multinational operations. Prior to harmonization, the same chemical could be classified differently across jurisdictions, complicating compliance and creating regulatory loopholes. 

Emergency responders and safety professionals identified critical gaps in older SDS versions. Information crucial during chemical accidents—such as clear hazard descriptions, specific decomposition products, and precise PPE requirements—was inconsistently presented or inadequately detailed. Additionally, certain suppliers were exploiting ambiguous concentration ranges and vague disclosure requirements to under-report hazardous ingredients, putting workers and environments at risk. 

Part 2: What Has Changed—Section-by-Section Breakdown 

Section 1: Identification 

• What changed: Emergency contact details are now required to be domestic and specific to the user’s country. Previously, manufacturers could list international or foreign emergency contact numbers. 

• Why it changed: First responders in emergencies need immediate access to qualified personnel in their own jurisdiction. A foreign emergency hotline provides no value during a workplace chemical incident requiring local expertise. 

• Practical impact: Importers must ensure Section 1 displays accurate domestic emergency contact information for their specific market. 

Section 2: Hazard Identification 

• What changed: Hazard classes and categories have been expanded and refined. New hazard categories include aerosol category 3, desensitized explosives (categories 1–4), pressurized chemicals under pressure (categories 1–3), and updated flammable gas subcategories (1A and 1B). Pictogram alignment has been revised to reflect these expanded categories, and hazard statements (H-codes) and precautionary statements (P-codes) have been reorganized with priority guidance. 

• Why it changed: Many chemicals were previously misclassified because older categories lacked the granularity needed for accurate hazard assessment. Enhanced classification provides workers with more precise hazard information. 

• Practical impact: Labels and SDS hazard sections require complete revision. Workers need updated training on new pictograms and hazard statements. 

Section 3: Composition/Ingredient Information 

• What changed: Acceptable concentration ranges have been narrowed. Exact percentages must be provided where feasible, with ranges permitted only where technically justified. Trade secret provisions no longer shield hazardous ingredient disclosure in emergency situations, and concentration thresholds for disclosure have been tightened across jurisdictions. 

• Why it changed: Under-reporting of ingredient concentrations allowed suppliers to technically comply while hiding significant hazards. Medical professionals and toxicologists require precise concentration data for accurate exposure assessment and treatment decisions. 

• Practical impact: Manufacturers must conduct thorough ingredient disclosure audits and revise formulation documentation to ensure accuracy. 

Section 4: First-Aid Measures 

• What changed: Symptom descriptions now distinguish clearly between acute and delayed effects. New warnings address outdated first-aid practices that medical organizations flagged as ineffective or harmful. Information specifies when immediate medical attention is required versus when home treatment suffices. 

• Why it changed: Inconsistent first-aid guidance in older SDSs led to inappropriate emergency response. Medical societies identified practices recommended in SDSs that contradicted current medical protocols. 

• Practical impact: First-aid response procedures in facilities must be updated, and first-aid kit contents may require adjustment to align with revised guidance. 

Section 5: Fire-Fighting Measures 

• What changed: Combustion product information has been updated based on modern laboratory data. Specific extinguishing media recommendations replace vague language like “use suitable extinguishing agents.” Thermal decomposition data is now differentiated from combustion products. 

• Why it changed: Modern fire science testing has produced more reliable data on chemical behavior during fires. Specific guidance prevents firefighters from selecting incompatible extinguishing agents that could exacerbate incidents. 

• Practical impact: Emergency response procedures and firefighter training require updates to reflect new extinguishing media recommendations. 

Section 6: Accidental Release Measures 

• What changed: Environmental release warnings are now stricter and more specific. PPE recommendations differentiate between emergency responders and non-emergency personnel, specifying appropriate protective clothing materials (e.g., “appropriate: butylene; not appropriate: PVC”). 

• Why it changed: Spill response teams identified vague PPE guidance as a source of inadequate protection. Specific material recommendations prevent selection of incompatible protective equipment. 

• Practical impact: Spill response kits must be re-evaluated, and personnel training material compatibility for protective equipment is essential. 

Section 7: Handling & Storage 

• What changed: New segregation rules for incompatible chemicals are more explicitly detailed. Ventilation requirements are specified more precisely rather than generically (“ensure adequate ventilation” now specifies ventilation type, volume, or system requirements). Conditions for preventing explosive atmospheres, maintaining stability, and controlling temperature are more comprehensive. 

• Why it changed: Warehouse incidents linked to vague SDS instructions revealed that generic handling guidance contributed to accidents. Enhanced specificity prevents mixing of incompatible chemicals and ensures proper storage conditions. 

• Practical impact: Warehouse layouts, storage procedures, and employee training programs require comprehensive updates. 

Section 8: Exposure Controls / PPE 

• What changed: Occupational exposure limits have been updated using current ACGIH, OSHA, and regional equivalents data. Respiratory PPE guidance is clearer, specifying respirator type (half-mask vs. full-face, specific filter cartridges). Engineering control recommendations include specific ventilation standards and system types. 

• Why it changed: Exposure limit research has evolved substantially, with new toxicological data supporting revised limits. Clearer respirator guidance prevents workers from selecting inadequate protection. 

• Practical impact: Workplace respiratory protection programs must be revised, and PPE inventories assessed for compliance with updated specifications. 

Section 9: Physical & Chemical Properties 

• What changed: Mandatory properties for certain substance types have been added (e.g., particle size characteristics for powders, dust deflagration index Kst for combustible dusts). Flammability data accuracy has improved through modern testing methods, and explosive properties are now explicitly addressed. 

• Why it changed: New formulations and updated testing methods revealed that older property data were insufficient for accurate hazard prediction. Enhanced property information enables better storage and handling decisions. 

• Practical impact: Chemical databases and inventory systems require updates to capture new property parameters. 

Section 10: Stability & Reactivity 

• What changed: Incompatible materials lists are more comprehensive and specific. Thermal decomposition information now includes temperature thresholds, specific decomposition products, and hazards associated with those products. Conditions to avoid are stated with greater precision. 

• Why it changed: New testing methods have produced more reliable decomposition data. Comprehensive incompatibility information prevents dangerous chemical reactions during storage and handling. 

• Practical impact: Segregation procedures in storage facilities must be revised to reflect expanded incompatibility data. 

Section 11: Toxicology 

• What changed: Chronic toxicity classifications have been revised with updated scientific evidence. Requirements for including specific toxicity data (when available) have been strengthened. New classifications for respiratory hazards and germ cell mutagenicity have been introduced. 

• Why it changed: Older SDSs relied on outdated toxicological studies, some decades old. Current research has identified previously unrecognized chronic health hazards. Workers deserve access to the latest scientific evidence. 

• Practical impact: Medical surveillance programs and occupational health protocols must incorporate updated toxicity information. 

Sections 12–15: Environmental, Disposal, Transport & Regulatory 

• What changed: Environmental hazard information is now aligned with EU CLP regulations, reducing regional inconsistencies. Transport information reflects IMO instruments and updated classification codes. Disposal guidance incorporates circular economy principles, emphasizing recycling and reclamation. Regulatory information sections now reference emerging restrictions like endocrine disruptors (EU 2023/707). 

• Why it changed: Global supply chains require consistent environmental and transport documentation. Emerging concerns (endocrine disruptors, persistent organic pollutants) necessitate updated regulatory information. 

• Practical impact: Shipping procedures, waste management protocols, and compliance tracking require updates across multiple departments. 

Section 16: Other Information 

• What changed: SDS revision history format is now standardized, and mandatory revision date clarity has been enforced. Version control is more rigorous, with clear indicators distinguishing outdated from current documents. 

• Why it changed: Facilities using outdated SDSs unknowingly exposed workers to hazards. Standardized revision history prevents confusion between versions. 

• Practical impact: Document management systems must enforce version control protocols strictly. 

Part 3: Why the Changes Matter 

1. Reduction in Worker Confusion

Standardized pictograms and hazard statements across suppliers provide consistent visual communication. Clearer handling rules translate directly to safer worker behavior. Consistency across suppliers eliminates conflicting guidance that confuses workers managing multiple chemicals. 

2. Easier Emergency Response

First responders receive standardized, readily accessible hazard information. Improved clarity on carcinogenicity, reactivity, and environmental hazards enable faster, more appropriate emergency decisions. Standardized format allows responders to locate critical information quickly during high-stress incidents. 

3. Better Global Trade & Compliance

Import/export compliance barriers are reduced when documents meet international standards. Regional inconsistencies no longer penalize manufacturers operating across multiple jurisdictions, streamlining global supply chains. 

Part 4: Practical Impact on Businesses 

1. What Businesses Must Update Immediately 

Chemical manufacturers and distributors must revise all product labels with updated hazard classifications, pictograms, and signal words. SDS repositories require comprehensive audits and updates to reflect new Section 2 classifications, ingredient concentration requirements, and exposure limits. Employee training must cover new hazard classes, pictograms, and workplace procedures reflecting updated Section 7 storage requirements. Disposal procedures must align with Section 13 guidance, and waste management contractors require notification of reclassifications affecting waste stream handling. 

2. Consequences of Relying on Old SDSs 

Misclassification penalties from OSHA and equivalent agencies range from $16,550 per violation (serious violation) to $165,514 per violation (willful or repeated). In fiscal year 2024, OSHA issued 527 citations for hazard communication violations, resulting in approximately $865,864 in total penalties. Incorrect PPE selection linked to inadequate Section 8 information has resulted in documented worker injuries, potentially triggering workers’ compensation claims and personal injury lawsuits. Failed compliance audits create regulatory liability and damage reputational standing with customers and partners. Increased legal liability arises from incidents where outdated SDS information contributed to worker harm. 

3. How SDS Software Helps Stay Compliant 

Modern SDS management software automatically checks for outdated hazard classes and alerts users to regulatory changes. Centralized SDS repositories ensure all locations access current versions, preventing reliance on obsolete documents. Version control systems maintain audit trails documenting when updates occurred and which personnel accessed documents. Cross-region compatibility features generate market-specific SDS versions meeting local regulatory requirements. 

4. Quick Comparison: Old vs. Updated GHS Requirements 

Conclusion 

The GHS SDS format changes represent a fundamental commitment to improving chemical safety through scientific rigor, international consistency, and worker protection. These updates are not optional for administrative refinements—they are mandatory compliance requirements affecting 95 percent of existing SDSs. The January 19, 2026, deadline for substances and July 20, 2026, deadline for mixtures create urgent timelines for manufacturers, distributors, and employers. 

Organizations that delay compliance face substantial legal and financial consequences. Beyond penalties, outdated SDSs expose workers to preventable injuries and create environmental liability. GHS is fundamentally a living system—updates will continue every two years as new scientific data emerges, and regulatory needs evolve. Proactive SDS management through digital tools, regular audits, and comprehensive employee training transforms compliance from a burdensome obligation into a strategic safety investment that protects both people and operations. 

The transition period is an opportunity for organizations to modernize their chemical management infrastructure, eliminate outdated documentation, and establish systems ensuring continuous compliance as regulatory standards continue to advance.