Part 310 min

3.3 Sections 9 to 16, and the four OSHA does not enforce

The back half of a safety data sheet is where people stop reading, which is a shame, because two of the most operationally useful sections live there — and four of them OSHA has stated outright it will not enforce. Knowing which is which saves time and stops arguments about sheets that are, by design, incomplete in places.

1 Section 9: physical and chemical properties

Section 9 reads like a data table and is treated like filler. It is not. Four of its entries change how a chemical behaves in a real space.

Flash point decides whether a liquid can be ignited at the temperature you are working in. Vapor density relative to air decides whether vapor collects at your feet, in a trench, in a pit, in a basement — or rises and disperses. Boiling point and vapor pressure together tell you how fast a spill fills a room with vapor. Solubility in water tells you what happens when it reaches the drain or the wash-down.

A worker who reads only section 2 knows the product is flammable. A worker who reads section 9 knows the vapor is heavier than air, and therefore why the sump is the dangerous part of the room.

On the job: for any product used in a pit, trench, tank or basement, take vapor density off section 9 and write it into the pre-task plan. Heavier-than-air vapor plus a low place is the mechanism behind a large share of confined-space fatalities.

2 Section 10: stability and reactivity

Section 10 is the section that tells you what your chemical will do to the chemical next to it. Under Appendix D it carries reactivity, chemical stability, possibility of hazardous reactions, conditions to avoid such as static discharge, shock or vibration, incompatible materials, and hazardous decomposition products.

Read together with section 7, handling and storage, it is the source of every segregation decision on your site: acids away from bases, oxidizers away from flammables and organics, cyanides nowhere near acids, chlorine-releasing products nowhere near ammonia-based ones. Those pairs are not general knowledge to a new hire; they are on the sheet.

The hazardous decomposition products line is the one that matters for hot work and for fires. A product that is inert on the shelf can produce something acutely toxic when heated — which is why 29 CFR 1926.353(c) names zinc, lead, cadmium, mercury, beryllium and chromium coatings for special treatment during welding, cutting and heating, and why section 10 belongs in the hot work permit conversation.

3 Section 11: toxicological information

Section 11 describes the health effects: the likely routes of exposure, symptoms related to the physical, chemical and toxicological characteristics, delayed and immediate effects and chronic effects from short- and long-term exposure, numerical measures of toxicity such as acute toxicity estimates, and whether the chemical is listed as a carcinogen by the National Toxicology Program, the International Agency for Research on Cancer or OSHA.

Two things make it worth reading. The routes of exposure line tells you whether the risk is what you breathe, what touches your skin, or what you swallow at break — and therefore whether ventilation, gloves or hand washing is the control that matters. The chronic effects line is where the hazards that never produce a bad day surface: the ones that show up in twenty years, which is exactly the shape of the asbestos, silica and lead risks that the substance-specific standards exist to manage.

4 Sections 12 to 15: present, ordered, and not enforced

Here is the part almost nobody knows. Paragraph (g)(2) carries two notes, and together they produce an unusual result.

Note 1 to paragraph (g)(2): to be consistent with the GHS, a safety data sheet must also include the headings in paragraphs (g)(2)(xii) through (g)(2)(xv) in order. Note 2 to paragraph (g)(2): OSHA will not be enforcing information requirements in sections 12 through 15, as these areas are not under its jurisdiction.

So the four sections must be there, and in the right order, but OSHA does not police what is written under them. They are: 12 Ecological information, 13 Disposal considerations, 14 Transport information, 15 Regulatory information. Each falls to another agency — EPA for the first two, the Department of Transportation for the third, and a mix for the fourth.

Sections 9 to 16 at a glance
Section	Content	Enforced by OSHA?
9 Physical and chemical properties	Flash point, vapor density, boiling point, solubility and the rest	Yes
10 Stability and reactivity	Incompatibles, conditions to avoid, decomposition products	Yes
11 Toxicological information	Routes, symptoms, acute and chronic effects, carcinogen listings	Yes
12 Ecological information	Environmental fate and effects	No — Note 2 to (g)(2)
13 Disposal considerations	Waste handling	No — Note 2 to (g)(2)
14 Transport information	UN number, shipping name, hazard class	No — Note 2 to (g)(2)
15 Regulatory information	Other regulations applying to the product	No — Note 2 to (g)(2)
16 Other information	Date of preparation or last revision	Yes

Common mistake: concluding that sections 12 to 15 are optional or can be deleted. Note 1 requires the headings, in order. What Note 2 removes is OSHA's enforcement of the information under them — and other agencies still care very much about sections 13 and 14.

5 Section 16: the date that tells you whether to trust the rest

Paragraph (g)(2)(xvi) names section 16 as Other information, including date of preparation or last revision. It is the shortest section and it is the first thing to check.

A revision date tells you where the sheet sits against the three-month update rule at (g)(5), and against the standard's own history. HazCom moved to the GHS format in 2012; a sheet in the old nine-section ANSI layout with a pre-2012 date is not a current safety data sheet, and the product it covers needs a new one requested under (g)(6)(iv).

Section 16 is also where a preparer will typically list the abbreviations used and any references — useful when a sheet is dense with acronyms your crew has not met.

6 A triage order for a sheet you have never seen

Sixteen sections is too many to read cold. This order gets a usable answer in about two minutes.

1
Section 16 — how old is this sheet? If it predates 2012 or looks nothing like this format, stop and request a current one.
2
Section 2 — what is it classified as, and is there a hazard not otherwise classified?
3
Section 8 — is there an exposure limit, what engineering control is expected, what PPE?
4
Section 7 and section 10 — where does it live and what must it not live next to?
5
Section 4 and section 6 — what do I do to a person, and what do I do to a spill?
6
Section 9 — flash point and vapor density, if this is used anywhere enclosed or below grade.

That sequence answers the practical questions in the order they get asked, and it leaves sections 12 to 15 for the people whose job they are.

Key takeaways

Section 9 carries flash point and vapor density — the two properties that decide behavior in an enclosed or low space.
Section 10 names incompatible materials and decomposition products; it is the source of segregation decisions.
Section 11 gives routes of exposure and chronic effects, including carcinogen listings.
Sections 12 to 15 must be present and in order, but OSHA states it will not enforce the information in them.
Section 16's revision date tells you whether the sheet is current at all.
A two-minute triage order beats reading sixteen sections: 16, 2, 8, 7 and 10, 4 and 6, then 9.

Free educational content — not OSHA-authorized training, no certificate or card issued. Follow your employer's program and the standards cited.