Relying on third-party Safety Data Sheets (SDSs) can expose a business to serious compliance, safety, and legal risks — especially under Australian WHS and GHS regulations. Here’s a detailed breakdown of the key dangers:

  1. Outdated or Non-Compliant SDSs
  • Regulations change frequently (e.g., GHS 7 → GHS 8, upcoming GHS 9 in 2025). Third-party SDS providers may not update documents promptly.
  • Using an outdated SDS means you could be classifying, labelling, or managing chemicals incorrectly — breaching WHS Regulations 2022 (WA) or equivalent state legislation.
  • Regulators (e.g., WorkSafe, EPA) can issue notices or penalties for using non-compliant SDSs.
  1. Inaccurate Hazard Classification
  • Many third-party SDSs use generic or global hazard data that doesn’t reflect Australian-specific classifications under the AICIS or Dangerous Goods Safety Regulations 2007 (WA).
  • This can result in:
    • Missing or incorrect DG classes, packing groups, or UN numbers.
    • Wrong or missing Pictograms, Signal Words, or H/P statements.
    • Misleading risk assessments or incorrect PPE recommendations.
  1. Incorrect Local Regulatory References
  • SDSs sourced overseas often cite EU REACH, US OSHA, or Canadian WHMIS legislation — not Australian WHS or AICIS frameworks.
  • This creates confusion for workers and auditors, and fails to meet the requirement that SDSs must be prepared in accordance with Safe Work Australia’s Code of Practice.
  1. Liability and Legal Exposure
  • If an incident occurs and the SDS information was wrong or incomplete, the importer, manufacturer, or supplier (not the third party) is legally responsible.
  • You can’t transfer this duty of care — regulators expect you to verify the SDS accuracy for each chemical used or supplied.
  1. Missing Toxicological or Ecological Data
  • Many generic SDSs omit or summarise toxicological and ecological information to save cost.
  • This makes it impossible to perform accurate risk assessments, NPI reporting, or waste management planning.
  1. Inconsistent Format or Missing Sections
  • Poorly formatted or incomplete SDSs can make it hard for workers to find critical data quickly (e.g., first aid, spill response).
  • The SDS must have all 16 sections clearly completed and compliant with Schedule 7 of the WHS Regulations.
  1. Loss of Control Over Revisions
  • If you rely on a third-party database, you often don’t know when an SDS was last updated or when it will expire.
  • Without an internal review system, your chemical register quickly becomes non-compliant and out of date.

Best Practice: Maintain Verified, Local SDSs

  • Require all suppliers to provide current (≤5 years old) Australian-compliant SDSs.
  • Use a chemical management system (like Lupin Chemical Management) that:
    • Tracks SDS expiry dates and updates automatically.
    • Verifies local regulatory compliance (AICIS, WHS, DG, GHS).
    • Allows internal review and version control.
    • Generates compliant labels and risk assessments directly from validated SDS data.