SDS Section 12: Ecological information

What OSHA requires in Section 12

OSHA includes the Section 12 heading in the 16-section format but does not enforce its content, because other agencies regulate this information. Other regimes, such as the GHS and the EU, still expect it.

Notes to paragraph (g)(2) of the HazCom standard say that, to be consistent with the GHS, an SDS must include the headings of Sections 12 to 15 in order, but that OSHA will not enforce the information in those sections because other agencies regulate it. Appendix D likewise describes Sections 12 to 15 as not mandatory. In practice a sheet is not out of compliance with HazCom merely because Section 12 is thin.

Appendix D describes the content that is customary for Section 12:

• Ecotoxicity (aquatic and terrestrial, where available).
• Persistence and degradability.
• Bioaccumulative potential.
• Mobility in soil.
• Other adverse effects, such as being hazardous to the ozone layer. (EU sheets also report endocrine disrupting properties here.)

Environmental duties for spills and releases are set by other laws, for example the US Environmental Protection Agency programs, not by OSHA HazCom.

GHS Annex 4 and international differences

The GHS includes aquatic hazard classes (acute and chronic) in the environmental hazard group, and GHS Annex 4 expects Section 12 to contain the supporting data: toxicity to fish, daphnia and algae, persistence and degradability, bioaccumulation potential (often via the partition coefficient or a bioconcentration factor), mobility in soil, and other adverse effects such as ozone depletion potential or endocrine disrupting potential. EU sheets add the results of the PBT and vPvB assessment.

In the EU the section matters more: environmental hazard classes are part of CLP and the REACH SDS has to contain the PBT/vPvB assessment where a chemical safety report exists. Sheets for the US market may include Section 12 data voluntarily, which is why you will sometimes see a US sheet with "no data" in this section while an EU sheet for the same product is detailed. See EU CLP for the classification side.

What to look for and red flags

What to look for

• Aquatic toxicity values (LC50 or EC50 for fish, daphnia, algae) with test duration.
• Biodegradability. "Readily biodegradable" and "persistent" imply very different disposal and spill priorities.
• Bioaccumulation indicators. A high partition coefficient or bioconcentration factor suggests accumulation in organisms.
• Mobility. Highly mobile and soluble substances can reach groundwater.
• Hazard to the ozone layer or other special environmental hazards.

Red flags

• "No data available" for every item on a product with an aquatic hazard classification (check how the classification was derived).
• Statements such as "not hazardous to the environment" with no supporting data.
• An EU-origin sheet for a product used in the US that has detailed environmental data but no description of how it relates to US reporting.

Worked example: typical fields

An illustrative layout. See the ecology section of the ethanol page for a sourced example drawn from public databases.

Toxicity

Aquatic values for fish, invertebrates and algae with test duration and species

Persistence / degradability

Biodegradation result or a statement of persistence

Bioaccumulation

Partition coefficient or BCF, and conclusion

Mobility in soil

Adsorption/desorption data or qualitative statement

PBT / vPvB

Result of assessment, where required

Other effects

For example ozone depletion or endocrine properties, if relevant

See how this looks on a real page: ethanol safety data, ecological information section. Every chemical page uses these 16 sections with the same anchors, so you can compare any substance.

Common mistakes

• Reading missing data as no hazard. It may only mean the test was never done for that product.
• Pouring "biodegradable" products down the drain. Biodegradability does not remove toxicity to aquatic life during the time it takes to degrade, and local rules may forbid the disposal.
• Using OSHA as the only compliance test. Waste, discharge and release rules come from environmental agencies.
• Confusing acute and chronic aquatic hazard. They are separate classifications with different test durations.
• Mixing up Section 11 and Section 12. Human health data lives in Section 11; ecotoxicology belongs here.

How Section 12 relates to other sections

Section 12 supports the environmental precautions in Section 6 and the disposal route in Section 13. Environmental hazards can also trigger special entries in Section 14 (for example the marine pollutant designation) and reporting duties in Section 15. Physical data such as the partition coefficient comes from Section 9.

Frequently asked questions