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MSDS vs SDS: is an old MSDS still OK in your register?

By SupplySafe Team Published Updated 5 min read

MSDS and SDS are the same document under two names. Safe Work Australia’s Code of Practice for preparing safety data sheets puts it in its first line: “A safety data sheet (SDS), previously called a Material Safety Data Sheet (MSDS), is a document that provides critical information about hazardous chemicals.”

So if someone asks for your “MSDS register”, they mean your SDS register, which the model Work Health and Safety (WHS) Regulations call a hazardous chemicals register. The name changed. The bigger question for a workshop is whether the sheets in the folder changed with it.

Why did MSDS become SDS?

Australia moved to the Globally Harmonised System of Classification and Labelling of Chemicals (GHS), the United Nations system used by many countries to classify chemicals and communicate their hazards on labels and safety data sheets. “SDS” is the GHS term, and it’s the term the model WHS laws use.

The GHS itself has editions. Safe Work Australia explains the latest change: during 2021 and 2022 Australia moved from the 3rd revised edition (GHS 3) to the 7th (GHS 7), and since 1 January 2023 GHS 7 must be used to classify and label hazardous chemicals in Australia.

Is an old MSDS still OK in my register?

Usually not, if it’s the only sheet you have. Two rules matter.

The register needs the current SDS. Regulation 346 of the model WHS Regulations requires the register to hold “the current safety data sheet for each hazardous chemical listed”. A sheet from before the manufacturer’s latest revision isn’t the current one.

The SDS you keep must be GHS 7. Safe Work Australia says: “SDS kept at the workplace must be compliant with GHS 7 from 1 January 2023 even if the label isn’t.” Where a chemical’s hazard classification changed with GHS 7, you must get the updated SDS from the manufacturer, importer or supplier when the chemical is first supplied to your workplace after the SDS is updated, or as soon as practicable after that first supply and before the chemical is used.

An old-format MSDS is a useful clue: the sheet predates the GHS rules, so it’s very unlikely to be current. It’s a prompt to get the current sheet, not something to throw away before you have the replacement.

What about old labels on stock?

Labels and sheets follow different rules. The Code of Practice says workplaces can keep using, storing and handling chemicals that were manufactured or imported before 1 January 2023 and labelled under GHS 3, and suppliers can on-sell that stock until it runs out. If the manufacturer updates the SDS for that stock, the supplier must give you the updated sheet the first time they supply the stock after the change.

So a tin with an older label on the shelf can be fine. The sheet in the register still has to be the current one.

How to tell an old MSDS from a current SDS

You don’t need to read the chemistry. Look at:

  1. The title. A sheet headed “Material Safety Data Sheet” is from the old system.
  2. The date. Every SDS must state the date it was last reviewed or, if it hasn’t been reviewed, the date it was prepared. The manufacturer or importer must review it at least once every five years, so a sheet more than five years past that date needs checking. Our guide to how long an SDS is valid explains the rule, and revision date vs issue date explains which date to read.
  3. The supplier details. A compliant SDS must be in English and state the name, Australian address and business telephone number of the manufacturer or importer, plus an Australian business telephone number for information in an emergency.

If any of those look wrong, ask the manufacturer or supplier for the current SDS. Most publish them on their website. Our guide to reading an SDS covers the rest of the sheet.

Who writes the SDS?

The manufacturer or importer, never the workshop. Regulation 330 of the model WHS Regulations says the manufacturer or importer of a hazardous chemical must prepare the SDS, review it at least once every five years and amend it whenever necessary to keep it correct and current. Your job as the workplace is to get the current sheet, keep it in the register, and make sure the people using the chemical can get to it.

Victoria

Victoria hasn’t adopted the model WHS laws. Its rules are in the Occupational Health and Safety Regulations 2017, and WorkSafe Victoria’s safety data sheets page says employers must obtain an up-to-date SDS for each hazardous substance or dangerous good they use or store. Different law, same practical answer: replace old sheets with current ones.

How SupplySafe handles it

SupplySafe doesn’t write or edit SDS. Manufacturers and suppliers publish their own current sheets to SupplySafe free, and SupplySafe staff check each one for completeness and dates before it goes into the shared catalogue. A workshop’s SDS register links each product to the manufacturer’s current sheet, flags any sheet whose review is due, and switches to the new revision when the manufacturer publishes one. If you’re a mechanic, see the SDS register for mechanics.

Replacing old MSDS? Our free hazardous chemical register template comes in Excel, PDF and CSV.

Frequently asked questions

What is the difference between an MSDS and an SDS?
The name, and the format behind it. Safe Work Australia's Code of Practice says a safety data sheet (SDS) was previously called a Material Safety Data Sheet (MSDS). Today's SDS is prepared under the Globally Harmonised System of Classification and Labelling of Chemicals (GHS), currently GHS 7 in Australia.
Is an MSDS register the same as an SDS register?
Yes, it's the same job under an older name. The model WHS Regulations call it a hazardous chemicals register: a list of the hazardous chemicals used, handled or stored at the workplace, with the current SDS for each one.
Can I keep an old MSDS in my chemical register?
The register needs the current SDS for each chemical. Safe Work Australia says SDS kept at the workplace must comply with GHS 7 from 1 January 2023, even if the product's label doesn't. An old-format MSDS is a sign to ask the manufacturer or supplier for the current sheet.
Do I have to throw out stock with an old label?
Not necessarily. Safe Work Australia says workplaces can keep using chemicals manufactured or imported before 1 January 2023 that were labelled under GHS 3. The SDS is different: the sheet you hold must comply with GHS 7.

Sources

This article is general information, not legal advice. It quotes and links the regulator's own wording; check the source and your state or territory regulator for anything that applies to your workplace. SupplySafe distributes Safety Data Sheets and does not author, edit or certify them. Rules change: see What's changing for dated, official updates.

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