SDS section 15 of 16
SDS Section 15: Regulatory information
Section 15 lists the safety, health and environmental regulations that apply specifically to the product, such as inventory status under TSCA, EPCRA/SARA listings, California Proposition 65 warnings or EU REACH status. OSHA does not enforce its content, so it varies a great deal between suppliers; treat it as a helpful starting point and not a complete compliance check.
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What OSHA requires in Section 15
OSHA includes the Section 15 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.
Section 15 is among the sections whose content OSHA will not enforce because other agencies regulate the information. Appendix D describes its content as safety, health and environmental regulations specific for the product in question.
In US sheets this commonly includes:
- TSCA inventory status of the substance (see EPA TSCA).
- SARA Title III / EPCRA listings, such as Section 313 toxic chemicals and extremely hazardous substances (see SARA Title III and EPCRA).
- CERCLA reportable quantities, where applicable.
- California Proposition 65 listings (see Prop 65).
- State right-to-know lists and other state rules.
GHS Annex 4 and international differences
GHS Annex 4 asks for safety, health and environmental regulations specific to the product, including any prohibitions or restrictions in the country of supply and status under conventions such as the Montreal Protocol and the Stockholm and Rotterdam Conventions. Typical items in sheets prepared for other markets include EU REACH registration or authorisation status, SVHC listing, restrictions, Seveso category, the chemical weapons convention and ozone-depleting substance lists, plus national inventories such as Canada's DSL, Australia's AIIC or Japan's ENCS.
Because the list of regulations is long and changes, Section 15 can fall out of date faster than other sections. Always check the revision date, and verify the status of a substance against the official source when compliance matters. For the EU context, see EU REACH, and for Canada see WHMIS.
What to look for and red flags
What to look for
- Inventory status for each country where you manufacture, import or sell.
- Reporting thresholds and listings you may have to act on, such as Tier II reporting or release reporting.
- Warnings required by law, such as Prop 65 for products sold in California.
- Restrictions or authorisation requirements in the EU or elsewhere.
- The date. Regulatory lists are revised frequently.
Red flags
- "None" or "not applicable" without saying which lists were checked.
- References to repealed legislation or to outdated risk phrases.
- US sheet with only EU information, or the other way around, for a product sold in the opposite market.
- A regulatory list that does not match Section 3's ingredients.
Worked example: typical fields
An illustrative layout for a US sheet. For public information on a real substance see the regulatory section of the ethanol page.
- TSCA
- Substance is listed on the TSCA inventory (active), or exemption notes
- SARA 302 / 304 / 311-312 / 313
- Applicable or not, with reportable thresholds if any
- CERCLA
- Reportable quantity, if any
- California Prop 65
- Listed chemical(s) and endpoint, or none
- International inventories
- Status for Canada, EU, Australia, and others
See how this looks on a real page: ethanol safety data, regulatory information section. Every chemical page uses these 16 sections with the same anchors, so you can compare any substance.
Common mistakes
- Assuming completeness. Section 15 is not a legal opinion and omits many local rules.
- Overlooking state law. US states have their own right-to-know and chemical rules.
- Treating "not listed" as "not regulated". It may only mean the supplier didn't check the list.
- Confusing hazard classification with regulatory listing. A chemical can be regulated for reporting even though it is not classified as hazardous under HazCom.
- Neglecting the effective date of the regulatory references.
Frequently asked questions
What belongs in Section 15 of an SDS?
Section 15 covers safety, health and environmental regulations specific to the product, including inventory status, reporting listings, product warnings and restrictions in the relevant countries.
Does OSHA enforce Section 15?
No. OSHA lists the heading but does not enforce its content, since the underlying rules belong to other agencies.
What is TSCA inventory status?
Under the US Toxic Substances Control Act, chemical substances manufactured or imported for most commercial uses must be on the TSCA inventory or be exempt. Section 15 commonly says whether the substance is listed.
Why does my SDS mention California Proposition 65?
Because the product contains a chemical on the Proposition 65 list and may be sold in California. Section 15 or a separate warning will say which chemical and for what type of harm.