SDS Under HazCom 2024 and WHMIS 2025: What a US/Canada Buyer Gets

After OSHA's 2024 Hazard Communication update and Canada's amended Hazardous Products Regulations, what should the safety data sheet accompanying a research reagent look like, and what should a buyer check on it?

A safety data sheet that accompanies a research reagent should follow the sixteen-section format used internationally, name the product, the supplier and the revision date, and match the label on the container. Since 2024 in the United States and since 14 December 2025 in Canada, the sheet should also reflect the seventh revision of the Globally Harmonized System of classification and labelling, known as GHS Revision 7. If it does not say which revision of the rule it follows, the buyer should ask.

The dates are the part most often misquoted. This article states them as published in the primary documents, notes the day they were checked, and then moves to the practical question: what should you look at when a sheet arrives with a new reagent, and what does an honest sheet for a research-use substance look like?

What changed in OSHA's 2024 rule

OSHA published the final rule updating the Hazard Communication Standard in the Federal Register on 20 May 2024 as 89 FR 44144 ^[2]. The standard sits at 29 CFR 1910.1200 and governs how chemical manufacturers, importers and distributors classify hazards and pass information down the supply chain, and how employers make that information available to workers ^[1].

The 2024 update aligned the standard with GHS Revision 7. In practice that touched hazard classification criteria for some categories, including flammable gases, aerosols and chemicals under pressure, and refined label and safety data sheet requirements. The rule also changed how labels are handled on small containers and on packages shipped in bulk, and added or clarified information that appears on the data sheet.

For a laboratory buyer the main consequence is document-related. A supplier updating its sheets to the new rule may issue a new revision of a sheet that you already hold. Old and new revisions may both be in circulation for some time.

The extended compliance dates

The 2024 rule set staggered compliance dates, with separate dates for substances and for mixtures, and for suppliers and for employers. On 15 January 2026 OSHA published a notice, 91 FR 1695, extending those dates by four months ^[3]. OSHA's stated reason was that it needed more time to publish guidance.

As stated in that notice, and checked on 10 October 2026, the dates are as follows. Many consultancy pages still carry the earlier dates, so check any secondary source against the Federal Register text.

The supplier date for substances has therefore passed. Sheets for single-substance reagents issued by US suppliers should now follow the updated format. Many research reagents are single substances, so this is the date most relevant to a laboratory buyer. The employer date for substances falls on 20 November 2026. Until the relevant dates arrive, OSHA has allowed compliance with the earlier version, the 2024 version or a combination, so a sheet in the older format is not automatically wrong.

Canada: the amended Hazardous Products Regulations

Canada's WHMIS is built on the Hazardous Products Act and the Hazardous Products Regulations, administered by Health Canada, with workplace provisions enforced by the provinces, territories and the federal labour programme ^[5][6]. Amendments to the regulations, aligning them with later GHS revisions, came into force in December 2022. A three-year transition period followed.

Health Canada's December 2025 newsletter confirms that the transition ended on 14 December 2025 and that hazardous products must now have classifications, safety data sheets and labels that fully comply with the amended regulations ^[4]. During the transition, suppliers could use the former or the amended rules, but not a mixture of the two for the same product. After it, the amended rules apply.

Canadian rules also require supplier safety data sheets to be available in both English and French. Separate provisions exist for laboratory reagents in small quantities and for laboratory samples, so the exact label and sheet obligations for a given container depend on its size and purpose. Check the current provisions on the Health Canada pages rather than assuming either an exemption or a full obligation.

The sixteen sections: what a buyer should read

Both countries use the same sixteen-section structure, so the checking routine is the same. A buyer is not expected to evaluate every technical entry. The aim is to confirm that the sheet describes the product in front of you and that its gaps are honest.

1. Identification: product name, supplier name and address, emergency telephone number. Does the name match the label?
2. Hazard identification: classification, signal word and pictograms, as they will appear on the label.
3. Composition: chemical identity and, where applicable, the registry number of the ingredient.
4. First-aid measures.
5. Fire-fighting measures.
6. Accidental release measures.
7. Handling and storage: the section that connects to your own storage record.
8. Exposure controls and 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, including the date of preparation or last revision.

Read sections 1, 2, 3, 7 and 16 first. Section 1 tells you whether the sheet is about your product and who stands behind it. Section 2 gives the classification the label should echo. Section 3 identifies what is in the container. Section 7 states supplier storage conditions that should be compared with how you actually hold the material. Section 16 gives the date that tells you how stale the sheet is.

Research-use substances and honest gaps

Many research compounds have not been fully characterised toxicologically. A sheet for such a substance will often state that no data are available for some endpoints. That is not a defect. It is the correct statement when testing has not been done, and the standards allow it.

What deserves a question is the opposite pattern: a detailed toxicological section for a novel compound with no cited source, or a sheet that classifies the product as non-hazardous while omitting the basis. Where a classification says "not classified", the underlying reason should be traceable, even if that reason is that data are lacking.

Checking the sheet matches the product

Compare the sheet with the container in your hand, field by field. The product name should be the same. The supplier named in section 1 should be the supplier on the label, or the label should name an identifiable producer. The hazard statements and pictograms on the label should agree with section 2.

Then read the revision date. A sheet with no date, or one dated years before the rules changed, may still be valid for an unchanged substance. It is also the most likely to be a copied or generic document. Ask the supplier whether the sheet has been reviewed since the update that applies to them, and note the answer.

Filing and retention

Treat the sheet as part of the lot record. File it with the certificate and the goods-in entry for the delivery, and note the revision date on the register. When a newer revision arrives, keep the old one, mark it superseded and record the date you replaced it.

The US laboratory standard, 29 CFR 1910.1450, separately expects laboratories to keep the sheets that arrive with incoming shipments and keep them accessible to the people working there. Canadian workplaces have a parallel duty under provincial and federal occupational health rules. Your own institution's policy may require more.

What to do next

Pull the sheets you hold for every reagent currently on the shelf. Note the revision date on each and flag any without one. Request current sheets from suppliers where the date predates the 2024 update. Add a line to your goods-in checklist for the sheet: present, matches product, dated.

If you are an employer in the United States, put 20 November 2026 in the diary for label and training updates. Read the Federal Register notice yourself rather than relying on a summary.