Updating a Safety Data Sheet for OSHA's HazCom 2024 requirements (29 CFR 1910.1200) involves five sequential steps: auditing your current SDS against the new standard, identifying which sections require changes, gathering any new required data, revising and reissuing the SDS, and updating downstream notifications. The substance deadline for manufacturers and distributors was May 19, 2026; the mixture deadline is November 19, 2027. This guide walks through each step in practical terms for US chemical manufacturers, importers, and distributors.
HazCom 2024 (29 CFR 1910.1200) requires SDS updates across Sections 2, 3, 9, and potentially others depending on your products' classifications. The process has five steps: audit, identify changes, gather data, revise and reissue, notify downstream users. Quantum SDS provides both self-serve authoring software updated for HazCom 2024 and a fully managed SDS update service — contact us to discuss your portfolio.
Step 1: Audit Your Current SDS Library Against HazCom 2024
Before you can update an SDS, you need to know what's wrong with it. Run a gap audit of your current SDSs against the HazCom 2024 standard. The key changes that will affect most manufacturers and distributors are:
- Section 2 (Hazard Identification): New hazard classes — Chemicals Under Pressure (from GHS Rev 8) and Desensitized Explosives (from GHS Rev 7). If any of your products fall into these new classes, Section 2 requires new hazard statements, pictograms, and signal words. Also: the new requirement to include classification based on reasonably anticipated downstream use conditions.
- Section 3 (Composition): Trade secret concentration ranges are now required where confidential business information (CBI) is claimed — generic ranges are no longer sufficient.
- Section 9 (Physical and Chemical Properties): Particle characteristics is now a required field for solid substances. Evaporation Rate is removed from the required list. "Appearance" is now "Physical State"; "Vapour Density" is now "Relative Vapour Density."
- Section 7 (Handling and Storage): Additional storage provisions required for flammable liquids where relevant.
- Labels (not SDS-specific but tied to same deadlines): New allowances for small and very small container labeling; new Aerosol and Flammable Gas classification rules affect label pictograms and signal words.
Work through your product list and flag each SDS with the specific changes required. Categorize products as substances vs. mixtures — this determines which deadline applies.
Step 2: Prioritize by Deadline and Risk
With the substance deadline at May 19, 2026 and the mixture deadline at November 19, 2027, substances should be addressed first. Within your substance portfolio, prioritize by:
- Products with the most downstream users — updated SDSs must be provided with the next shipment after the SDS is revised (29 CFR 1910.1200(g)(9)). High-volume products affect the most customers and carry the most reputational risk if delayed.
- Products in the new hazard classes (chemicals under pressure, desensitized explosives, revised aerosols, revised flammable gases) — these require the most substantive SDS changes and should be started earliest.
- Products where particle characterization data does not currently exist — data gathering takes time, especially if analytical testing is required.
Step 3: Gather the Required Data
Some HazCom 2024 changes require new data that may not currently exist in your SDS authoring system:
- Particle characteristics: If you manufacture solid substances, review whether particle size, shape, surface area, and dustiness data is available in your formulation records or QC testing. If not, determine whether supplier data can support the disclosure or whether testing is needed.
- Downstream use classification: Section 2 under HazCom 2024 requires consideration of hazards from known or reasonably anticipated downstream uses. Review how your product is typically used — if a product is sold as a component that customers will heat, dissolve, or mix with other chemicals, document the hazard implications.
- Trade secret concentration ranges: If you claim CBI for any ingredient under Section 3, prepare to disclose a concentration range rather than a specific value. Work with your regulatory counsel on the appropriate range boundaries.
Step 4: Revise and Reissue
Update the SDS using either SDS authoring software that is updated for HazCom 2024 (which will handle the property list changes in Section 9 automatically and flag classification issues) or an SDS authoring service. When revising:
- Update the revision date.
- Document the specific changes made in Section 16 (Other Information) — listing HazCom 2024 as the reason for revision is best practice and simplifies downstream communication.
- Verify that the 16-section format, section ordering, and all headings comply with 29 CFR 1910.1200, Appendix D.
- For multilingual SDSs (required for products sold in Canada under WHMIS, or into EU markets under CLP/REACH), ensure all language versions are updated simultaneously — distributing an updated English SDS while French or Spanish versions remain on the 2012 format creates a compliance inconsistency.
Step 5: Notify Downstream Users
Under 29 CFR 1910.1200(g)(9), chemical manufacturers and importers must provide revised SDSs to distributors and employers with or before the next shipment after an SDS revision. Practical steps:
- Update your SDS management system or document library with the revised versions and archive the superseded versions. Retention rules apply.
- Notify customers proactively — a brief email communication listing updated products and where to access the new SDSs is both good practice and a documented compliance effort.
- If you use a SDS distribution service, confirm that the service has pushed the updated versions to all downstream users.
- Update your written Hazard Communication Program to reference HazCom 2024 and include updated SDSs.
Frequently Asked Questions
Can we still use our 2012-format SDSs during the transition period?
Yes, until your applicable deadline. OSHA permits compliance with either the 2012 or 2024 standard until the deadline date. After November 20, 2026 (substances), only the 2024-compliant SDS is acceptable.
Do we need to update SDSs for products that haven't changed chemically?
Yes. The update obligation is triggered by the regulatory change, not by a formulation change. Even if your product chemistry hasn't changed since 2012, the SDS format requirements under HazCom 2024 have.
What is the fastest way to update a large SDS library?
For portfolios of 50 or more SDSs, a managed SDS authoring service or automated SDS authoring software is significantly faster than manual revision. Quantum SDS offers both options.
Need Help Updating Your SDSs for HazCom 2024?
Quantum SDS offers SDS updating services and HazCom 2024-ready authoring software. Our regulatory team has 30+ years of SDS authoring expertise across OSHA, WHMIS, REACH, and global GHS. Get your portfolio compliant before the deadline.
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