SDS Revision Comparison Checklist: Check All 16 Sections
Summary
A safety data sheet (SDS) revision comparison checklist needs 4 sections: document identity, a 16-section old-versus-new comparison, effect on existing approvals, and follow-up actions. Product stewards, quality and purchasing staff fill it when a supplier's revised sheet arrives. It fits 16-section sheets under EU REACH and Canadian WHMIS rules, and US OSHA sheets, where sections 12 to 15 are optional.
A US safety data sheet preparer who becomes newly aware of significant hazard information must add it to the sheet within three months (OSHA 29 CFR 1910.1200(g)(5), 2026).
A revised EU safety data sheet shows "Revision: (date)" on the first page with the version it replaces, and the changes are flagged in section 16 unless indicated elsewhere (Regulation (EU) 2020/878, Annex II, 2020).
Under the updated US Hazard Communication Standard, manufacturers, importers and distributors evaluating substances had to comply by May 19, 2026, and those evaluating mixtures must comply by November 19, 2027 (OSHA, 2026).
In Canada, a supplier has no requirement to provide an updated safety data sheet to past purchasers (CCOHS, 2026).
Who uses an SDS revision comparison checklist, and what do they decide?
An SDS revision comparison checklist is used by whoever receives a revised safety data sheet for a product already in use: a product steward, an environment, health and safety officer, a quality engineer, or a distributor's technical staff. Its job is to decide one of three things: file the new version and replace the workplace copy, update the workplace documents that draw on it, or re-check an existing product approval.
The revised safety data sheet usually arrives without a request. In the US, chemical manufacturers and importers must provide an updated sheet with the first shipment after it is updated, and distributors must pass it on the same way (OSHA 29 CFR 1910.1200(g)(6), 2026). In the EU, a supplier who updates a sheet for new hazard or risk management information, an authorisation or a restriction must send it to every recipient supplied within the preceding 12 months (REACH Article 31(9), consolidated 2026).
The reader of the finished safety data sheet checklist is the person who owns the approval or the workplace documents: the one who signs that labels, storage, exposure assessments and customer approvals still match. A distributor fills a second copy when the revision has to be passed on to its own customers, because the same comparison tells it which customers need to hear about which change.
Which sections does the SDS revision comparison checklist have?
The SDS revision comparison checklist has 4 sections, and each one ends in a decision the next section uses. The table below previews them with the form of each entry and an example entry marked illustrative.
Checklist section | What goes in it | Unit or form | Example entry (illustrative) |
|---|---|---|---|
1. Document identity | Product, supplier, jurisdiction format and language, old and new version numbers, revision dates, where the revision note sits | Version; YYYY-MM-DD; checkbox | Version 3.0 of 2025-11-02 against 4.1 of 2026-03-20 (illustrative) |
2. Section-by-section comparison | Header and sections 1 to 16, each with old value, new value, status and whether it reaches an approval | Same, changed or unknown; yes or no | Section 9 flash point changed, reaches approval yes (illustrative) |
3. Effect on existing approvals | Each approval or document that relied on the old sheet, the basis it used and the verdict | Holds, re-check or re-evaluate | Customer approval re-check (illustrative) |
4. Follow-up actions | Questions to the supplier, actions with owner and date, distribution and archiving | What, who, by when | Ask supplier about reformulation by 2026-04-10 (illustrative) |
The decisive section is section 3: a comparison that finds changes but never maps them to approvals leaves the real question open. Fill section 1 before reading the new sheet, so the comparison starts from the version your approval used, not the one before it or a copy from a portal. Record in section 1 how the sheet arrived, by shipment, email or supplier portal, and on which date, because updating workplace copies and passing the sheet on to your own customers start from that date. Section 2 is filled side by side, and section 4 closes the case with a sign-off. The editable Word checklist, with a blank copy and an illustrative filled copy, is at the end of this page.
What should you compare in each of the 16 SDS sections?
In each of the 16 safety data sheet sections, compare the values a downstream decision uses: classification, composition, limits, properties and transport data, plus the header that identifies the version. The table lists what to compare old against new for the header and every section, with the unit or form and an illustrative example.
SDS section | What to compare old against new | Unit or form | Example value (illustrative) |
|---|---|---|---|
Header | Version number, revision date, version superseded | Version; YYYY-MM-DD | 4.1, 2026-03-20, supersedes 3.0 (illustrative) |
1. Identification | Product identifier, other identifiers, recommended use and restrictions, supplier, emergency number, UFI (EU) | Text; code | New supplier address (illustrative) |
2. Hazard identification | Hazard classes and categories, signal word, pictograms, hazard and precautionary statements | Class and category; H and P codes | Eye irritation category 2 added (illustrative) |
3. Composition | Chemical name, CAS number, concentration or range of each listed component; EU limits, M-factors, ATE | CAS number; % by weight or range | Range 1 to 5% narrowed to 1 to 3% (illustrative) |
4. First aid measures | Exposure routes, symptoms, medical attention | Text | No change (illustrative) |
5. Firefighting measures | Extinguishing media, combustion hazards | Text | No change (illustrative) |
6. Accidental release | Spill precautions, containment, cleanup | Text | New containment step (illustrative) |
7. Handling and storage | Storage conditions, incompatible materials | °C; text | Storage limit 40 °C lowered to 30 °C (illustrative) |
8. Exposure controls | Exposure limits per component, controls, protective equipment | mg/m3 or ppm; glove material | New limit listed for one component (illustrative) |
9. Physical and chemical properties | Flash point, pH, density, viscosity and their methods | °C; g/cm3; mm2/s | Flash point 62 °C to 58 °C (illustrative) |
10. Stability and reactivity | Incompatible materials, conditions to avoid, decomposition products | Text | No change (illustrative) |
11. Toxicological information | Acute toxicity values, routes, health effects | mg/kg; text | New skin irritation result (illustrative) |
12. Ecological information | Ecotoxicity, persistence, mobility | mg/L; text | No change (illustrative) |
13. Disposal considerations | Waste treatment methods | Text | No change (illustrative) |
14. Transport information | UN number, shipping name, transport class, packing group | UN number; class; group | No change (illustrative) |
15. Regulatory information | Rules and listings that apply to the product | Text; list | New listing named (illustrative) |
16. Other information | Revision date, indication of changes, abbreviations | YYYY-MM-DD; text | Note names sections 2, 3 and 9 (illustrative) |
The row that decides most cases is section 3, because a composition change means an approval was proven on a different product. Under US rules, Appendix D marks sections 12 to 15 as non-mandatory (OSHA 29 CFR 1910.1200 Appendix D, 2026), so an empty section there on a US sheet is not by itself a change; record it as unknown if your approval used it. In the Word file, every row also carries a status and a reaches-approval box; tick them for rows with no change too, so the record shows that each section was read.
How do you match components between two SDS versions?
Match components between two safety data sheet versions by CAS number first, then by concentration or range, and treat the chemical name only as a cross-check. Names, synonyms and the order of listing can change between versions without any change in the product.
Under US rules, section 3 of a mixture's sheet gives the chemical name, CAS number or other unique identifier, and concentration or concentration ranges of ingredients classified as health hazards that are present above their cut-off limits or present a health risk below them (OSHA 29 CFR 1910.1200 Appendix D, 2026). Two consequences follow for the comparison. A component that disappears from section 3 may have been removed, reclassified, or reduced below its cut-off limit, so its absence alone is unknown, not removed. And unclassified components never appear, so an unchanged section 3 does not prove an unchanged formula.
Ranges need care. A US sheet may use concentration ranges instead of exact percentages when a trade secret is claimed, when there is batch-to-batch variability, or for a group of substantially similar mixtures (OSHA 29 CFR 1910.1200 Appendix D, 2026). A narrower or shifted range is a change; a switch from an exact value to a range is unknown until the supplier explains it. On EU sheets, also compare the specific concentration limit, M-factor and acute toxicity estimate given for each substance, which Annex II requires "if available" (Regulation (EU) 2020/878, Annex II, 2020).
Which SDS sections change an existing product approval when revised?
The safety data sheet sections that most often change an existing product approval when revised are section 3 for composition, section 2 for hazard classification, and section 9 for a physical property the approval tested or specified. A revision reaches an approval when it touches the basis that approval rested on, and leaves it standing otherwise.
Write the basis down before comparing: the specific findings the approval relied on, such as a test result, a flash point limit, a restricted-substance check or the absence of a hazard class. Then each changed row in section 2 of the checklist gets one of three verdicts in section 3:
Holds, when the change touches nothing in the basis, such as a new address or reworded first aid text.
Re-check, when the change touches a use condition, such as section 8 protective equipment, section 7 storage or section 14 transport, which affects controls and logistics but not product performance.
Re-evaluate, when the change touches the basis itself, such as a section 3 composition change or a section 9 property outside the approval limit.
A changed hazard class in section 2 can fall in either of the last two, depending on whether the approval required the product not to carry that class. Workplace documents drawn from the sheet, such as secondary labels, exposure assessments and training material, follow the same comparison and are listed in section 3 of the checklist as well.
What should you ask the supplier about a revised SDS?
Ask the supplier of a revised safety data sheet what changed, why, and from which lot, because the sheet itself may not say. EU rules require a revised sheet to give a clear indication of where changes were made, and add that "A supplier of a substance or mixture shall be able to provide an explanation of the changes upon request" (Regulation (EU) 2020/878, Annex II, 2020). US rules require only the date of preparation or last change in section 16 (OSHA 29 CFR 1910.1200 Appendix D, 2026).
Send the questions in writing and record the answers in section 4 of the checklist:
Which sections changed, and what was the reason: new hazard data, a classification rule change, a reformulation, a raw material or manufacturing site change, or format only?
Was the product reformulated, including components not listed in section 3?
From which lot or production date does the new version apply?
Did the technical data sheet, specification or certificate of analysis limits change at the same time?
Does the revision apply in every market, or only to the jurisdiction this sheet is written for?
The answer to question 1 sets the scope of the review. A format-only revision, such as a conversion of an EU sheet to the Annex II format that has applied since 1 January 2021 (Regulation (EU) 2020/878, 2020), still deserves a side-by-side check, because a formatting rewrite can carry one real change among many cosmetic ones.
SDS revision comparison example (illustrative)
The SDS revision comparison example below is illustrative: the product, values and dates are invented to show how a filled comparison reads. A water-miscible cutting fluid moves from version 3.0 of 2025-11-02 to version 4.1 of 2026-03-20, and the approval on file was a customer trial on aluminium machining.
SDS section | Old version 3.0 (illustrative) | New version 4.1 (illustrative) | Status and reach (illustrative) |
|---|---|---|---|
Header | 3.0, 2025-11-02 | 4.1, 2026-03-20, supersedes 3.0 | Changed; identity only |
2. Hazard identification | Skin irritation category 2 | Skin irritation 2, eye irritation 2 | Changed; reaches labels and protective equipment |
3. Composition | Third component 1 to 5% | Third component 1 to 3% | Changed; reaches approval |
8. Exposure controls | Gloves, nitrile | Gloves, nitrile; safety goggles | Changed; reaches workplace controls |
9. Physical and chemical properties | pH 9.0 to 9.6 at 5% dilution | pH 9.0 to 9.6 at 5% dilution | Same |
14. Transport information | Not regulated | Not regulated | Same |
16. Other information | First issue note | Sections 2, 3 and 8 revised | Changed; matches rows above |
In this illustrative case the narrowed range in section 3 reaches the trial approval, so the verdict is re-evaluate for that finding and re-check for labels and protective equipment. The pH result the trial relied on is unchanged, so that part of the approval stands. Read the reach column before the status column, because a changed row that reaches nothing, such as the header, leaves the approval as it was. Section 4 of the checklist then records the supplier answers; in this case whether the narrowed range reflects a reformulation is still open. The remaining rows, sections 1, 4 to 7, 10 to 13 and 15, are marked the same way and are left out here for length.
Why do SDS revision reviews miss changes?
SDS revision reviews miss changes mainly because the new sheet is compared with the wrong old version, or not compared at all because the revision date looked routine. Five patterns account for most misses.
First, the comparison starts from the latest file in the folder instead of the version the approval used. If one revision was filed without review, the next comparison hides its change.
Second, the revision date is taken as the review. A date shows that the sheet changed, not what changed, and a US sheet has to give only the date of preparation or last change (OSHA 29 CFR 1910.1200 Appendix D, 2026).
Third, the section 16 note is trusted as complete. The EU text requires a clear indication of where changes were made (Regulation (EU) 2020/878, Annex II, 2020), but a short note such as "sections 2 and 3 updated" does not say what moved inside them.
Fourth, revision waves bury real changes. The updated US Hazard Communication Standard has compliance dates of May 19, 2026 for those evaluating substances and November 19, 2027 for those evaluating mixtures (OSHA, 2026), so many sheets are being reissued in that window, and a reformulation can arrive inside a regulatory update.
Fifth, no updated sheet arrives at all. In Canada there is no requirement to provide one to past purchasers (CCOHS, 2026), so a buyer there may need to ask for the current version before every comparison.
When is a side-by-side SDS checklist not enough?
A side-by-side SDS checklist is not enough when the question goes beyond what a safety data sheet discloses, when the approval rests on performance, or when one change spans many products. The checklist compares two documents; it cannot see what neither document contains.
Four situations need more than the checklist. When the full formula matters, for example for a food-contact or restricted-substance declaration, section 3 is not sufficient because unclassified components are not listed, and the supplier has to confirm in writing. When the approval rested on a performance trial and section 3 changed, the checklist only flags that a requalification is needed; the trial is planned and run separately. When the sheet was written for another jurisdiction than the site where the product is used, compare the sheet issued for that site. When a supplier revises a whole product line, one impact review across all affected products and customers replaces one checklist per sheet.
The checklist also does not replace the author's review of a sheet before publication, which checks classification, completeness and label consistency; a pre-publication checklist adds that "The final reviewer should also confirm that the SDS applies to the current formulation and intended market" (CHEMTREC, 2026). When the product is reordered, Lubinpla's reorder review uses the previous and new SDS in your data room to check whether the changed items reach the existing suitability decision, keeps the findings they leave untouched, and returns one cited document for review, with your approval at each step.