GHS / Safety Data Sheet (SDS) – Hazard Communication

This topic is part of the SG Systems Global regulatory & operations glossary.

Updated October 2025 • Chemical Classification, Labeling, SDS Lifecycle • EHS, Manufacturing, QA/RA, Supply Chain, Packaging

GHS (Globally Harmonized System) is the world’s lingua franca for classifying and communicating chemical hazards. The Safety Data Sheet (SDS) is its technical backbone, and the label is the face customers and operators see. In compliant operations, SDS + label + training form a closed loop: the recipe knows the hazard, the equipment respects the hazard, and the shipping docs tell the truth. In weak operations, hazard data lives in scattered PDFs, labels are retyped by hand, and trainings devolve into box‑ticking. The unvarnished reality: hazard communication fails not because people don’t care, but because systems aren’t designed to deliver the right facts to the right person at the right second—on the floor, on the line, and at the dock.

“If the label and the SDS disagree, the drum is a lawsuit waiting for a forklift.”

1) What GHS/SDS Covers—and What It Does Not

Covers: classification of physical, health, and environmental hazards; standardized label elements and SDS format; rules for mixtures (bridging, additivity); supplier responsibilities; and downstream communication to workers, emergency responders, and customers. It also touches transport alignment and multilingual needs. Does not cover: all transport‑only requirements or sector‑specific claims (e.g., drug labeling). GHS sets the hazard‑communication language; your QMS must prove you use it consistently in production and distribution.

2) Legal, System, and Data Integrity Anchors

GHS is implemented via jurisdictional rules. Electronic SDS/label systems supporting regulated operations must meet Part 11/Annex 11 (where applicable): validated platforms (CSV/GAMP 5), unique users (UAM), immutable audit trails, and governed retention. If hazard data drives labels, MES interlocks, and shipping documents, treat it like any other GxP‑critical master: version‑controlled and testable on demand—not a PDF graveyard.

3) SDS Structure—The 16 Sections (and Why They Matter)

An SDS has a fixed architecture so responders and operators can find facts fast. In brief: (1) Identification; (2) Hazard(s) identification; (3) Composition/Information on ingredients; (4) First‑aid measures; (5) Fire‑fighting measures; (6) Accidental release measures; (7) Handling and storage; (8) Exposure controls/Personal protection; (9) Physical and chemical properties; (10) Stability and reactivity; (11) Toxicological information; (12) Ecological information; (13) Disposal considerations; (14) Transport information; (15) Regulatory information; (16) Other information. Author them once, use them everywhere—but never freehand; feed key fields from validated sources (LIMS, supplier COAs, exposure limits database) and lock the rendered PDF under Document Control.

4) Classification Basics—Physical, Health, Environmental

GHS classifies hazards into families (flammability, oxidizers, corrosivity, acute/chronic toxicity, aspiration, STOT, carcinogenicity, reproductive toxicity, aquatic toxicity, etc.) with categories that drive label elements and SDS statements. Don’t guess: use validated methods, published cutoffs, and expert rules. Then record the rationale—an auditor must be able to reconstruct why you picked “Danger” vs. “Warning” and which data triggered a pictogram. This is not a branding exercise; it’s a risk disclosure with legal weight.

5) Mixture Rules—Bridging & Additivity

Few products are pure substances; most are mixtures. GHS applies bridging principles (e.g., dilution, batch‑to‑batch consistency) and concentration cutoffs to infer mixture classifications when direct data is incomplete. Build mixture logic into your authoring engine and tie it to item master data under Recipe Management. If a supplier changes an ingredient classification or concentration, fire a NoC and route via Change Control before production or shipping labels change. No silent reformulations.

6) Labels—Pictograms, Signal Word, H & P Statements

A compliant label presents the product identifier, signal word (Danger/Warning), pictograms (flame, skull, corrosion, gas cylinder, oxidizer, health hazard, exclamation, environment), hazard statements, precautionary statements, and supplier contact. Your label engine should consume the same master data as the SDS—no retyping. Enforce print‑time checks with Label Verification; bind lot/serial via Serialization/SSCC; and block shipment if hazard elements are missing or stale. Labels are not graphic design—they’re legal statements tied to traceability.

7) Sector Nuances—Drugs, Cosmetics, Foods

GHS is hazard communication; it does not replace sector labeling rules. Pharma batches still live under 21 CFR 211 for manufacturing and release; cosmetics follow ISO 22716 for GMP and ingredient declarations (INCI); foods require 21 CFR 117 and HACCP. You’ll often need both: GHS for handling/transport and sector labels for claims/ingredients. Harmonize rather than stack contradictions.

8) Authoring Pipeline—From Data to SDS

Build a disciplined authoring workflow: (1) gather substance data from COAs, lab tests, and literature; (2) validate methods (TMV) and quantify measurement noise (MSA) through a competent lab (ISO/IEC 17025); (3) classify hazards; (4) generate SDS and labels; (5) route electronic approvals; (6) publish to MES/WMS/portal; (7) keep translations in sync. Manage raw data in LIMS/ELN, not inboxes.

9) Multilingual & Market Versions

Hazard statements and precautionary phrases have controlled translations; free translation invites liability. Maintain a translation library bound to the classification engine and render SDS/labels per target market. Version every language separately under Document Control. If you cannot prove which language version was shipped with a lot, your traceability is incomplete—period.

10) Change Control—When to Reissue

Reissue SDS/labels upon any classification change, significant composition shift, new hazard data, regulatory updates, or process changes that alter exposure (e.g., lower flash point due to solvent swap). Route through formal Change Control with impact assessment and effective dates. Archive superseded versions per Retention rules. “We’ll update next quarter” is not a defense if an incident occurs tomorrow.

11) Supplier Governance—Keep COA and SDS Honest

Classifications often hinge on supplier data. Qualify vendors (VQ/SQM) and incoming lots (Incoming Inspection, sampling plans). When supplier SDS and your lab disagree, pause use and reconcile under Deviation/CAPA. Chronic misalignment warrants a SCAR—do not grade your own homework with optimistic assumptions.

12) Inventory & WMS—Gating on Hazard Facts

Your WMS should know hazards, not just SKUs. Gate putaway to compliant zones, enforce segregation (oxidizers vs. organics), and require current SDS before release. Tie pick/pack to hazard labels and ship only when labels/SDS are in force. Publish ASN with hazard identifiers and generate EPCIS events so downstream partners receive the right documents automatically.

13) Point‑of‑Use—SDS on the Line

Operators need SDS access where they work—not on a distant PC. Expose SDS via workstation links, HMI buttons, and QR codes on bins. Block hazardous steps in MES if SDS is missing or obsolete. Link PPE requirements in SDS Section 8 to enforced checks in the work instruction (Digital Work Instructions). Safety that depends on memory is wishful thinking.

14) Training & Competence—Prove They Know

Hazard comm training is not a single slide deck. Use a Training Matrix with role‑based modules (read a label, find SDS sections, don PPE, respond to spills). Track completion, proficiency, and refresh cycles; gate access to hazardous operations until competencies are current. Tie exceptions to Hold/Release in the MES. If a person can start a hazardous phase without training, your controls are cosmetic.

15) Emergency Response—SDS Meets Reality

Sections 4–6 and 10 translate straight to SOPs: first aid, firefighting, spill control, incompatibilities. Author response SOPs, keep them current with SDS updates, and drill. Tie alarms and shutdowns to SCADA/HMI interlocks; document events in the eBMR and investigate under Deviation. Prepared plants have smaller incidents and better investigators.

16) Environment & Waste—Downstream Duties

Sections 12–13 (ecology and disposal) inform waste codes, compatibility, and contractor instructions. Bind waste streams to recipes and record volumes via Mass Balance. Map storage conditions with Temperature Mapping and track atmosphere where needed under Environmental Monitoring. If your waste manifests don’t reconcile with consumption, you don’t have environmental control—you have a guessing problem.

17) Digital Thread—One Truth from Authoring to Dock

Hazard data must flow, not be retyped. Wire SDS/label masters into the MES to drive work instructions and PPE prompts; into WMS for storage, segregation, and shipping; into LIMS for exposure limits and methods; and into portals for customer access. Serialize containers and link them to SDS versions and labels. If a customer scans a QR and gets an outdated SDS, your digital thread has snapped—and so has your defense at inspection time.

18) Data Integrity—Reconstructable, Not Reassuring

Every hazard classification, phrase selection, translation, and label render must be attributable and reproducible (ALCOA(+)). Use audit trails with reason codes for edits; store baselines and diffs; and bind approvals to user accounts under UAM. Backups and restores must be tested. “It looked right” is not evidence; reconstructable arithmetic and documents are.

19) Common Pitfalls & How to Avoid Them

• PDF sprawl. SDS stored in email threads; labels built in Illustrator. Centralize under Document Control.
• Retyping into labels. Drive labels from the SDS master and verify prints with Label Verification.
• Blind mixture math. No documented rationale for categories or pictograms. Capture rules and cutoffs; make the logic testable.
• Training theater. One‑time slides, no role‑based refreshers. Use a governed Training Matrix.
• Label/SDS mismatch at ship. WMS must hard‑block pick/pack if the SDS or label element is stale.
• Translation drift. Free translations of hazard phrases. Use controlled libraries and lock with versioning.
• Zero integration. If SCADA/HMI can’t pull SDS or PPE, you’ve left the last mile to memory.
• Change control gaps. Supplier NoC bypasses authoring. Route via Change Control every time.
• Overlapping frameworks. Transport vs. GHS vs. sector labels not aligned. Design composite labels that satisfy each without contradiction.
• “We’ll fix it at audit.” You won’t. Hazard comm must work in real time or it doesn’t work at all.

20) Metrics That Prove Control

• SDS currency rate (% lots with current SDS attached in WMS/MES).
• Label/SDS parity incidents and time‑to‑correction.
• Training compliance (on‑time completion by role) and PPE adherence at point‑of‑use.
• Pick/ship blocks due to missing hazard artifacts (should trend toward zero with process maturity).
• SCARs due to misclassified inputs and COA‑to‑SDS deltas.
• Incident/near‑miss rate with linkage to SDS sections invoked and effectiveness of CAPA.
• Translation defect rate detected by markets.

Good metrics trigger decisions—supplier changes, retraining, label engine upgrades—not just dashboards for comfort.

21) Pack & Ship—Last‑Mile Truth

Cartons, cases, and pallets must carry the right hazard labels and identifiers. The WMS should assemble mixed‑hazard shipments with segregation rules, print correct outer‑pack labels, and attach SDS at shipment. Publish ASNs that include hazard info and link to current SDS. Use EPCIS to make the digital twin of each logistic unit queryable by customers and regulators. If the truck leaves with wrong labels, that’s not a warehouse error—that’s a system error.

22) What Belongs in the Hazard Communication Dossier

Classification rationales and mixture math; SDS in all languages/markets with approval signatures and effective dates; label templates and rendered examples per SKU/market; translation libraries; training curricula and completion evidence; supplier COAs and verification plans; NoCs and resulting change controls; system validations (CSV/GAMP 5), IQ/OQ/PQ for label devices; audit trails for edits; WMS/MES gating logic; and incident/CAPA history. Store under Document Control with retention plans.

23) How This Fits with V5 by SG Systems Global

One source of hazard truth. The V5 platform stores classification data, SDS masters, and label elements as versioned objects. Labels render directly from the same data the SDS uses; Label Verification scans enforce parity on the floor.

Execution & interlocks. V5 exposes SDS at point‑of‑use, enforces PPE prompts in work instructions, and blocks hazardous steps when SDS or training is missing. The WMS gates putaway by hazard and prints compliant outer‑pack labels; shipments publish hazard details through EPCIS/ASN.

Evidence & improvement. Every edit is captured with audit trails; dashboards show SDS currency, block events, and label parity; exceptions open Deviation workflows and close via CAPA. Bottom line: V5 turns hazard comm from paperwork into live control.

24) FAQ

Q1. Do we need an SDS for every internal mixture?
If employees handle it or it ships externally, treat it like a product: classify, author, and publish. Internal intermediates used solely within a contained process may leverage workplace labels and internal SDS access—document your rationale.

Q2. How do we keep labels and SDS in sync?
Drive both from a single master with approved translations and auto‑render labels at print time. Block pick/pack when versions diverge; require electronic sign‑off for exceptions.

Q3. Who approves SDS changes?
Cross‑functional: EHS for classification, QA/RA for compliance, and Supply Chain/Packaging for label impacts. Route via formal Change Control with effective dates and market rollout plans.

Q4. How often must we retrain workers?
At onboarding, upon process/material changes, and periodically per risk and policy. Use a governed Training Matrix and gate hazardous operations until refreshed.

Q5. What if a supplier’s SDS conflicts with our testing?
Quarantine the material, investigate under Deviation, and reconcile data through Lab (MSA/TMV). Escalate via SCAR if systemic.

Q6. How do we handle multilingual SDS at scale?
Use controlled phrase libraries tied to classification; version each language; validate layout and line breaks; and publish to portals and pack‑docs through the WMS. Never free‑translate hazard phrases.

Related Reading
• Systems & Integrity: MES | WMS | LIMS | ELN | Audit Trail | Document Control
• Quality & Governance: Change Control | Deviation | CAPA | Record Retention | UAM
• Packaging & Distribution: Label Verification | Serialization | SSCC | ASN | EPCIS
• Safety & Ops: SOP | Training Matrix | SCADA | HMI | EM | Temperature Mapping