SDS Updates After Formulation Changes: Timing & Compliance

Safety Data Sheet (SDS) Update Requirements After Formulation Changes

Safety Data Sheets (SDSs) are essential documents that communicate the hazards, safe handling practices, and risk control measures for chemical substances and mixtures. They play a critical role in workplace safety by helping employers, workers, emergency responders, and supply chain partners understand how to manage chemicals safely.

While SDSs do not “expire” like food products, global regulations require them to be updated whenever relevant changes occur—particularly following changes to a product’s formulation.

What Triggers an SDS Update?

An SDS must be updated whenever new, significant information becomes available that affects the product’s hazards, composition, or risk management measures. Common triggers include:

• Changes to the chemical formulation or ingredient concentrations

• New hazard data arising from testing, scientific findings, or regulatory updates

• Revised regulatory classifications under systems such as the Globally Harmonized System (GHS), which may trigger a GHS SDS update

• Updates to recommended workplace control measures or personal protective equipment (PPE)

When any of these changes occur, the SDS can no longer be considered “current” because it no longer accurately reflects the true nature of the product.

Is There a 24-Hour Rule for SDS Updates?

There is no single, globally applicable regulation that mandates SDS updates within 24 hours of every formulation change. SDS update requirements vary by country and regulatory framework:

• European Union (EU – REACH): SDSs must be updated without delay when new hazard information or other relevant changes become available. The updated SDS must be provided to all recipients who received the product in the previous 12 months. However, REACH does not specify a strict 24-hour deadline.

• United States (OSHA Hazard Communication Standard): Manufacturers and importers must update SDSs within 90 days of becoming aware of new hazard information or changes to protective measures.

• Canada (WHMIS): SDSs must generally be updated within 90 days of receiving “significant new data.”

That said, some organizations—particularly in industries where formulation changes can have serious safety implications—adopt faster internal timelines, such as 24-hour internal review or draft preparation processes. These timelines reflect best practices in safety management rather than explicit legal requirements.

Why Rapid SDS Updates Are a Best Practice

Even when regulations do not mandate a 24-hour update, rapidly revising SDSs after formulation changes offers clear advantages:

• Worker Safety: Accurate, up-to-date hazard and exposure information ensures employees can handle new formulations safely.

• Regulatory Compliance: Proactive updates reduce the risk of non-compliance, enforcement actions, and penalties related to outdated hazard communication.

• Supply Chain Transparency: Distributors and downstream users rely on SDSs to assess risk—timely updates build trust and prevent miscommunication.

• Emergency Preparedness: In the event of spills, exposures, or fires involving a new formulation, emergency responders need current and reliable hazard data.

Practical Tips for Effective SDS Management

• Monitor formulation changes: Establish internal triggers so any formulation or raw material change automatically initiates an SDS review.

• Use SDS management software: Digital tools help track SDS versions, revision dates, and global distribution requirements.

• Communicate with suppliers: Ensure upstream formulation or classification changes are communicated promptly.

• Document updates: Maintain clear records of SDS versions, revision dates, and reasons for change to support regulatory audits.

Conclusion

While most major chemical safety regulations do not require SDS updates within 24 hours of a formulation change, they do require SDSs to be updated without delay whenever new hazard, composition, or risk management information becomes available. Many organizations implement rapid internal update timelines to align safety practices with regulatory intent and operational risk.

Staying proactive with SDS updates protects workers, strengthens regulatory compliance, and builds confidence across the supply chain.

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