When manufacturing, importing, or even using chemical products, we often come across the Safety Data Sheet (SDS). We discuss what this document is and when it is required in other articles; in this text, however, we want to explain how an SDS is created, focusing on the most important stages of this process. We hope that understanding the basic steps involved in preparing an SDS will be useful when gathering product data or when working independently on documentation.

Product Data – the Starting Point for the SDS

Collecting the right data is a key element of most business activities – and the same applies to Safety Data Sheets. As the name suggests, the SDS describes the “characteristics” of the product, including its properties and hazard profile. To provide such a description of a substance or mixture, it is essential to first understand it – and this can only be achieved by gathering sufficient information.

To assess the characteristics of a chemical product, we must know above all:

• its chemical composition – a “must have”; without it, it will be difficult to evaluate potential hazards or possible reactions with other chemical mixtures,

• its intended use – this helps assess potential exposure routes and levels of exposure,

• physicochemical properties – from critical ones, such as flash point or viscosity (where relevant), to color or odor, which may help users identify the product,

• toxicological and ecotoxicological data for the product or its components,

• type and size of packaging,

• specific storage conditions.

Based on the above, we can proceed to the next stages of SDS preparation, where these data are translated into the specific format and language of the Safety Data Sheet.

Hazard Assessment – CLP Classification of the Product

After gathering the necessary data, the first and most critical step in SDS preparation is carrying out the product’s CLP classification. Using available information on composition and properties, and applying the methods described in the CLP Regulation, we prepare what can be called a hazard profile. The outcome of this step is a description of hazards arising from product use, expressed through H-statements as defined in the regulation.

By including the classification (in Section 2.1 of the SDS), we inform the reader about what hazards the product may pose (e.g. corrosive, flammable, or explosive properties).

Classification also forms the basis for developing the following sections of the SDS. For instance, it guides the choice of emergency procedures or personal protective equipment. This is why proper classification is such a critical element of SDS preparation and one of the aspects most carefully checked by inspections.

Label Elements – the Key Tool for Communicating Hazards

Section 2.2 of the SDS presents the label elements of the chemical product, which must then be reflected on the product label. This is extremely important because the CLP label is the primary tool used by a company placing a chemical product on the market to inform the end user of hazards. This applies especially to consumer products, as consumers are not SDS recipients – for them, the label is the only source of product information.

Label elements are closely linked to classification. They are selected on that basis. In addition to H-statements and EUH-statements describing hazards, appropriate pictograms are chosen, along with P-statements (here, knowledge of product use and the type of user is particularly useful).

Correct preparation of the CLP label is a critical step in documentation because changing labels after printing and applying them to products involves significant costs and operational challenges.

Product Composition – Section 3 of the SDS

After completing classification and labeling, we move on to Section 3 of the SDS, which describes product composition. It is important to remember that this section does not usually present the full formulation of the mixture, but only those substances whose disclosure is required under the REACH Regulation. Depending on the product type and substances used, Section 3 may list dozens of components, or none at all (and in both extreme cases the SDS may still be fully compliant).

Preparing Section 3 requires analyzing the classification of individual components, their impact on the classification of the entire product, and determining whether they must be listed based on their concentration in the product. This part of the SDS is also subject to frequent and detailed inspections.

Section 14 – Transport of Dangerous Goods

Another section of the SDS relies heavily on external regulations: Section 14, which (where applicable) specifies how the product should be transported. This section contains information drawn from relevant dangerous goods transport regulations (depending on the mode of transport, these may be ADR, IMDG Code, or IATA rules).

Transport classification assessment and assignment of the appropriate UN number is also a very important element of SDS preparation.

Other Sections of the SDS

Once the key sections – Sections 2, 3, and 14 – are prepared, we can proceed with the remaining sections. These are also very important, but Sections 2, 3, and 14 largely define what we find in the rest of the SDS.

Regulation (EU) 2020/878 specifies what should be covered in each section, but unlike the key sections, it does not dictate how the information should be presented. It is therefore up to the SDS author to describe product hazards, first aid measures, safe handling practices, or selection of protective equipment.

Of course, there are many industry-standard phrases that appear in most SDSs, and they form the basis of documentation. However, in special cases, non-standard or even unique wording may be required for a given product type or chemical substance.

The ability to provide precise and adequate descriptions of product characteristics and safe handling is an indispensable skill for every professional SDS author. The quality of these descriptions determines how well the SDS fulfills its role.

It is also worth noting that knowledge of waste regulations (Section 13) or occupational exposure limits (Section 8) is often necessary when preparing these sections.

Section 15 – Regulatory Information

Once all other sections are prepared, we move on to Section 15, where the product is assessed against applicable regulations (national and EU). This is where we indicate, for example, whether the product is subject to REACH restrictions, whether it contains SVHCs, or whether an authorization has been granted. Assessing these regulatory aspects is also an important step in SDS preparation.

Summary

In short, preparing an SDS can be divided into the following stages:

• data collection,

• CLP classification (Section 2),

• label elements (Section 2),

• composition assessment (Section 3),

• transport classification (Section 14),

• filling in SDS content (other sections),

• regulatory assessment (Section 15).

This is therefore a complex process requiring specialist knowledge, primarily of the CLP and REACH Regulations, but also of other related legislation – from the transport of dangerous goods to occupational exposure limits.