Guide

GHS, CLP and HazCom: SDS, Labels and Poison-Centre Notification

The Globally Harmonised System (GHS) is the UN framework for chemical hazard classification, labelling and Safety Data Sheets. Regional implementations diverge: the EU's CLP (Regulation EC 1272/2008) and OSHA HazCom 2012 (updated 2024 to GHS Rev 7) are the two largest, with Canada (WHMIS 2015), UK CLP, Japan, Korea and ASEAN running their own variants. A single SDS that satisfies all jurisdictions verbatim rarely exists; most manufacturers maintain region-specific SDS from a common source. CLP additionally requires poison-centre notification with a Unique Formula Identifier (UFI) printed on the label. This guide walks the structure and the recurring inspection failures.

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Hazard classification — bridging principles and the C&L Inventory

GHS classification covers physical hazards (explosives, flammables, oxidisers, gases under pressure, self-reactives), health hazards (acute toxicity, skin/eye irritation, sensitisation, CMR, STOT, aspiration) and environmental hazards (aquatic acute/chronic, ozone). For mixtures, bridging principles (dilution, batching, concentration, interpolation) apply when test data is absent. The ECHA C&L Inventory is the harmonised source for substances with Annex VI binding classification under CLP; OSHA HazCom uses the same GHS criteria but does not maintain a centralised binding list.

The 16-section SDS and what inspectors test

Both CLP (Annex II) and HazCom (29 CFR 1910.1200(g)) require the 16-section SDS in fixed order: Identification, Hazard ID, Composition, First Aid, Firefighting, Accidental Release, Handling/Storage, Exposure/PPE, Physical/Chemical Properties, Stability/Reactivity, Toxicology, Ecology, Disposal, Transport, Regulatory, Other. Inspectors most often test Section 2 (does it match Section 3 composition?), Section 8 (are OEL/PPE current?), Section 14 (does it match the actual UN number/packing group used in shipping?) and Section 15 (REACH/TSCA/Prop 65 status accurate?).

Label elements, supplemental info and EUH statements

GHS labels carry the pictogram(s), signal word (Danger/Warning), H-statements and P-statements derived from classification. CLP adds EU-specific EUH statements (e.g. EUH208 for sensitiser disclosure, EUH210 for SDS-on-request) and supplemental information. Small-package derogations under CLP Article 29 allow reduced labelling for very small immediate containers (typically ≤125 mL) but the SDS and outer packaging must carry full information. UFI must be printed on the label when CLP Annex VIII applies.

EU poison-centre PCN, UFI and the duty under CLP Annex VIII

Annex VIII to CLP requires importers and downstream users placing hazardous mixtures on the EU market to submit harmonised PCN (Poison Centre Notification) information to ECHA's PCN portal and print the resulting UFI on the product label. The duty is staggered by use category — consumer (since Jan 2021), professional (Jan 2021), industrial (Jan 2024). The UFI is product/composition-specific; a change above the defined thresholds (composition, classification, trade name) triggers a new UFI and a relabelling cycle.

Revision discipline — the trigger map

An SDS revision is triggered by new hazard information (classification change), new uses, new exposure controls, a CMR/PBT/vPvB finding, a Candidate List addition (Article 33), a registration update, or any other change material to safe use. Inspectors trace whether the trigger reached the revision date, whether downstream customers received the updated SDS under Article 31(9) (within 12 months for material changes), and whether the label and PCN/UFI followed. Revision-discipline failure is the single most common HazCom/CLP finding.

Standards covered in this guide

Each standard, retailer code or assurance scheme referenced above has its own deep-dive page with scope, audit detail and common pitfalls.

MSDS / SDS

Standardised 16-section hazard document required for every hazardous chemical (OSHA HazCom 2012 / GHS).

Where this lives in V5 Ultimate

The clauses above aren't theoretical — every one maps to a shipped module and an industry profile. Jump to the parts of the product that turn this guide into evidence on a Monday morning.

Modules that do the work

SDS revision control

Trigger map with audit trail and customer push.

Classification master

C&L Inventory linkage, bridging principles, history.

PCN / UFI workflow

Per-member-state notifications and relabelling.

Industries this hits hardest

Specialty & Industrial Chemicals

Frequently asked

Is the 2024 HazCom update aligned with GHS Rev 9?

The 2024 HazCom Final Rule aligns OSHA with GHS Rev 7 (with selected Rev 8 elements). It is not aligned to Rev 9. Compliance dates are staggered through 2026–2027 for substances and mixtures. CLP is currently aligned to GHS Rev 8 with the 21st ATP; both will trail Rev 9 by years.

Do I need a UFI on every product sold in the EU?

Only hazardous mixtures classified for health or physical hazards under CLP and placed on the EU market for the relevant use category trigger Annex VIII. Substances (not mixtures) and non-hazardous mixtures are out of scope. Mixtures classified only for environmental hazards are also out of scope under the current text.

Can one SDS serve both CLP and HazCom?

In practice, no. While both follow GHS structure, the divergence in classification criteria, Section 15 regulatory references, EUH statements, OEL sources and language requirements makes region-specific SDS necessary. Most manufacturers maintain a single classification source and generate per-region SDS automatically.

How quickly must a revised SDS reach customers?

Under REACH Article 31(9), if a substance/mixture is reclassified, restrictions are introduced, exposure scenarios change or new hazard information becomes available, the updated SDS must be provided free of charge to all recipients to whom the substance/mixture was supplied in the previous 12 months. OSHA HazCom requires 'within three months of new information' for labels and SDS.

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