And yet, we see the same mistakes over and over again. Not because companies don't care, but because SDS requirements are genuinely complex, they vary by country, and the consequences of getting them wrong aren't always immediately visible. Until they are.
Here are the five most common SDS mistakes we encounter in our review work, and what you can do about each one.
1. Generated for the Wrong Country, or Simply Translated from Another Country's SDS
This is the single most common issue we see, and it's often the hardest to catch without expertise. A company selling in the United States receives an SDS from their overseas manufacturer, often generated for the EU, China, or another market, and assumes it's sufficient for U.S. distribution.
Sometimes the document has simply been translated into English, with no adjustment to the regulatory framework. The hazard classifications may follow EU CLP criteria rather than OSHA's Hazard Communication Standard (HCS). The exposure limits may reference European occupational limits instead of OSHA PELs or ACGIH TLVs. The emergency contact number may route to an overseas call center with no 24-hour U.S. coverage.
Under OSHA's Hazard Communication Standard (29 CFR 1910.1200), an SDS distributed in the United States must comply with U.S. regulatory requirements, not just be "in English." The 16-section GHS format is required, but the content within those sections must reflect U.S.-specific regulations, exposure limits, and emergency response expectations.
Reference: OSHA Hazard Communication Standard, 29 CFR 1910.1200 osha.gov/laws-regs/regulations/standardnumber/1910/1910.1200
2. Not Displaying Required Ingredients, or Displaying Too Much (or Too Little) Information
Section 3 of the SDS (Composition/Information on Ingredients) is where we see some of the most consequential errors. Companies either under-disclose or over-disclose, and both create problems.
Under-disclosure happens when hazardous ingredients are omitted, listed at incorrect concentrations, or hidden behind vague descriptions like "proprietary blend." While trade secret protections do exist under HCS, they come with specific obligations, including the requirement to disclose the information to health professionals in emergencies.
Over-disclosure is less discussed but equally problematic. Some manufacturers list every trace ingredient regardless of concentration or hazard relevance, which can trigger unnecessary downstream requirements (additional PPE, special storage, or even shipping restrictions) that don't actually apply to the product as formulated.
The key is accuracy. OSHA requires disclosure of hazardous ingredients at or above certain concentration thresholds (generally 1% for health hazards, 0.1% for carcinogens). Getting this right requires understanding both the formulation and the regulatory thresholds.
3. Not Calling Out Prop 65 When Required
California's Proposition 65 (the Safe Drinking Water and Toxic Enforcement Act of 1986) requires businesses to provide "clear and reasonable" warnings before knowingly exposing individuals to chemicals listed under the Act. The list currently includes over 900 chemicals known to cause cancer, birth defects, or other reproductive harm.
If your product contains a listed chemical above the applicable threshold and you sell into California, whether in person or online, you may need a Prop 65 warning. Many companies either don't realize their product triggers Prop 65, or they include a generic warning that doesn't meet the current "safe harbor" requirements.
Since August 2018, safe harbor warnings must include the name of at least one listed chemical, the specific type of harm (cancer, reproductive harm, or both), and the URL www.P65Warnings.ca.gov. Generic "this product contains chemicals known to the State of California..." language without specifics no longer qualifies.
Reference: California OEHHA Proposition 65 oehha.ca.gov/proposition-65
4. Not Including a 24-Hour Emergency Help Line
Section 1 of the SDS requires an emergency phone number that is available 24 hours a day, 7 days a week. This isn't optional. It's not a "nice to have." It's a regulatory requirement under both OSHA HCS and DOT regulations for shipped hazardous materials.
We regularly see SDS documents with a standard business phone number listed as the emergency contact, a number that goes to voicemail at 5 PM. In an actual emergency (a spill, an exposure, a transportation incident), that voicemail isn't going to help anyone. And from a compliance standpoint, it doesn't meet the requirement.
Companies like CHEMTREC, INFOTRAC, and 3E provide 24-hour emergency response services specifically for this purpose. The cost is typically modest relative to the compliance risk of not having one.
Reference: CHEMTREC Emergency Response Services chemtrec.com
5. Treating the SDS as a "Set It and Forget It" Document
An SDS is a living document. It needs to reflect the current state of your product, the current regulatory landscape, and the current understanding of the hazards involved. But many companies create an SDS once, at product launch, and never revisit it.
OSHA requires that SDS documents be updated when new information becomes available about the hazards of a chemical, or when the composition changes. Even if nothing changes, best practice (and many customer requirements) call for a review at least every three years.
We cover this topic in depth in our article on when you need to update your SDS.
The Bottom Line
None of these mistakes happen because companies are negligent. They happen because SDS compliance is genuinely complex, and the people responsible for it often have a dozen other responsibilities competing for their attention.
If any of these sound familiar, you're not alone. And the good news is that every one of them is fixable. The first step is knowing what to look for.