16.2. Date of Preparation/Revision of the SDS
Subsection 16.2 of a Safety Data Sheet provides information about when the SDS was initially prepared and subsequently revised. This information is crucial for ensuring users have the most current safety information and for tracking changes over time. It helps users determine if they are working with the most up-to-date version of the document.
Purpose and Importance
The date of preparation/revision serves several critical functions:
Currency
Allows users to verify they are working with the most recent safety information, which is particularly important when regulations or hazard classifications change.
Traceability
Provides a chronological record of changes to the SDS, which is important for documentation, auditing, and compliance purposes.
Compliance
Helps demonstrate compliance with regulatory requirements for periodic review and update of safety information.
Risk Management
Enables users to identify when new hazard information or risk management measures have been incorporated into the SDS.
Regulatory Requirements
While specific formatting requirements for revision information may vary by jurisdiction, most regulatory frameworks require that the date of preparation or last revision be clearly indicated on the SDS:
- GHS: Recommends including the date of preparation or the date of the last revision
- REACH (EU): Requires indication of when the SDS was revised, with identification of the changes made
- OSHA HazCom (US): Requires the date of preparation or last revision
- WHMIS (Canada): Requires the date of the latest revision
- Safe Work Australia: Requires the date of preparation or last review
Key Components of Revision Information
Date Format
The date should be clearly presented in a format that avoids ambiguity. Best practice is to use the ISO 8601 format (YYYY-MM-DD) or to spell out the month to avoid confusion between different date formats (e.g., January 15, 2024).
Examples:
- 2024-01-15
- January 15, 2024
- 15 January 2024
Version Number
A version number or identifier helps track the evolution of the SDS over time. Common formats include:
- Sequential numbers (e.g., Version 1, 2, 3)
- Major.minor format (e.g., Version 3.2)
- Date-based versions (e.g., Version 2024-01)
Change Description
A summary of the changes made in the current revision helps users identify what information has been updated. This may include:
- Sections that were modified
- Nature of the changes (additions, deletions, corrections)
- Reason for the update (e.g., new regulatory requirements)
- Impact on hazard classification or risk management measures
Document Control Information
Additional information that may be included:
- Document identifier or reference number
- Previous version reference
- Next scheduled review date
- Approval information (prepared by, reviewed by, approved by)
- Distribution status (e.g., controlled document)
Revision History Timeline
A comprehensive SDS may include a revision history that tracks changes over time. This example shows the evolution of an SDS through multiple revisions:
Initial release
- First issue of the Safety Data Sheet
- Based on initial product formulation
- Compliant with GHS Revision 7
Major update
- Product formulation change
- Updated hazard classification in Section 2
- Revised toxicological information in Section 11
- Updated first aid measures in Section 4
Minor update
- Updated regulatory information in Section 15
- Added new exposure limits in Section 8
- Corrected typographical errors
Major update
- Reformulation of product
- Updated physical and chemical properties in Section 9
- Revised hazard classification in Section 2
- Updated ecological information in Section 12
- New transport requirements in Section 14
Minor update
- Updated supplier contact information in Section 1
- Added new regulatory information in Section 15
- Expanded abbreviations list in Section 16
Minor update
- Updated regulatory information in Section 15
- Revised transport requirements in Section 14
- Updated exposure controls in Section 8
- Added new safety measures in Section 7
Scheduled comprehensive review
- Full review of all sections
- Update to GHS Revision 9
- Incorporation of new test data
- Alignment with updated regulatory requirements
Example of Section 16.2 Content
16.2 Date of Preparation/Revision
Current Version: 3.2
Date of Issue: 2024-01-15
Previous Version: 3.1 (2023-11-05)
Next Review Due: 2025-01-15
Changes in Current Version:
- Section 15: Updated to reflect new regulatory requirements under REACH Regulation
- Section 14: Revised transport classification based on updated test data
- Section 8: Updated occupational exposure limits in line with latest ACGIH recommendations
- Section 7: Added new safety measures for handling based on industry best practices
Document Control:
- Document ID: SDS-2024-001
- Prepared by: J. Smith, Safety Department
- Reviewed by: A. Johnson, Technical Manager
- Approved by: M. Williams, Quality Control
- Distribution Status: Controlled document
SDS Review Frequency
The frequency of SDS reviews and updates depends on several factors:
| Trigger | Description | Action Required |
|---|---|---|
| New Information | New data becomes available about hazards or risk management measures | Immediate update required |
| Formulation Change | Changes to the composition of a mixture | Immediate update required |
| Regulatory Changes | New or revised regulations affecting classification or SDS content | Update within regulatory timeframe |
| Periodic Review | Regular review even without specific changes | Typically every 3-5 years |
| Supplier Information | Updated information from raw material suppliers | Update as soon as practicable |
| Incident or Near Miss | Safety incidents revealing new hazard information | Immediate update required |
Note: While many jurisdictions do not specify a mandatory review frequency, it is generally considered good practice to review SDSs at least every 3-5 years, even if no changes are needed. Some companies adopt more frequent review cycles (e.g., annual) as a best practice.
Case Study: SDS Revision Management System
A global chemical manufacturer implemented a comprehensive SDS revision management system to ensure timely updates and clear communication of changes:
- Challenge: Managing over 5,000 SDSs in 30+ languages across multiple regulatory jurisdictions
- Solution: The company:
- Implemented an automated SDS authoring and management system
- Established a version control system with clear naming conventions
- Created a centralized database of revision histories
- Developed a change tracking system that automatically identified affected sections
- Implemented a notification system for customers when significant changes occurred
- Revision Documentation: Each SDS included:
- Clear version number and date in a consistent format
- Detailed description of changes by section
- Indication of whether changes affected hazard classification or risk management measures
- Digital signature trail showing who prepared, reviewed, and approved the revision
- Outcome: The system ensured that all SDSs remained current and compliant, with clear documentation of changes that helped users quickly identify important updates. The company reported a significant reduction in customer inquiries about SDS currency and improved regulatory compliance.
Common Issues with Revision Information
When preparing or reviewing Section 16.2 of an SDS, be aware of these common issues:
- Ambiguous dates: Using date formats that can be misinterpreted (e.g., 01/02/2024 could be January 2 or February 1)
- Missing version numbers: Failing to include a version identifier that distinguishes between different revisions
- Vague change descriptions: Providing generic statements like "updated as needed" without specifying what changed
- Inconsistent formatting: Using different date formats or version numbering systems across SDSs
- Outdated SDSs: Failing to update SDSs when new information becomes available or regulations change
- Incomplete revision history: Not maintaining a record of previous versions and changes
- Conflicting information: Having different dates in different sections of the SDS
Best Practices for Section 16.2
- Use a clear, unambiguous date format (preferably ISO 8601: YYYY-MM-DD)
- Include a version number or identifier that clearly distinguishes between revisions
- Provide specific information about what sections were changed and the nature of the changes
- Indicate whether changes affect hazard classification or risk management measures
- Maintain a revision history that allows tracking of changes over time
- Include document control information (prepared by, reviewed by, approved by)
- Specify the next scheduled review date
- Ensure consistency in date formats and version numbering across all SDSs
- Implement a system to ensure timely updates when new information becomes available
- Consider highlighting or marking changed sections in the SDS to make updates more visible
Important: Users should always ensure they are referring to the latest version of the SDS. Previous versions should be removed from circulation or clearly marked as superseded to prevent the use of outdated safety information. Companies should have a system in place to notify users when significant changes are made to an SDS, particularly when those changes affect hazard classification or risk management measures.