SDS revision date, issue date or print date: which one matters?

The SDS revision date, meaning the date the sheet was last reviewed, is the one that matters. If the sheet has never been reviewed, use the date it was prepared instead. That’s the only date the model WHS Regulations require on the sheet, and the five-year review clock runs from it.

Everything else (print date, “first issued”, and friends) is extra. Handy context sometimes, but not the date to judge a sheet by. Here’s how to tell them apart in about thirty seconds.

Why does one SDS carry so many dates?

Pick up a few SDS from the shelf and you’ll see dates everywhere. A typical header might read something like “Issue date: 03/2015 · Revision date: 11/2024 · Print date: 14/10/2026”. Others add a “Supersedes” date, a version number, or a “valid until” line.

None of that is wrong. SDS are produced with authoring software and templates, and each template has its own habits. The trouble starts when someone picks the wrong date to measure the sheet against.

SDS date of preparation or last review: which date does the law require?

Schedule 7 of the model WHS Regulations sets out what an SDS must contain. On dates, it says an SDS must:

state the date it was last reviewed or, if it has not been reviewed, the date it was prepared

Safe Work Australia’s guidance puts it like this:

All SDS must list the date when it was last reviewed and updated. This date is usually written in Section 16 – Any other relevant information, of the SDS.

Victoria runs its own Occupational Health and Safety Regulations 2017 rather than the model WHS laws, but WorkSafe Victoria’s list of required SDS content includes the same idea: “date of preparation or last review”. WorkSafe Victoria also says an SDS developed to meet another Australian jurisdiction’s hazardous substances legislation “will also comply with the Victorian OHS Regulations.”

What you won’t find is a print date or a “first issued” date. Neither Schedule 7 of the model WHS Regulations nor Safe Work Australia’s model Code of Practice for preparing SDS asks for either. They’re template conventions. Useful for the manufacturer’s own records, but not the date the rules are built around.

The Code does recommend one extra thing. It says an SDS “should include a version number, superseded date or some other indication of what version is replaced.” So a version number or “Supersedes” line is good practice, but the regulation itself asks for the review date.

The dates at a glance

Date on the sheet	What it usually means	Use it for the five-year review?
Revision date / date of last review	When the manufacturer last reviewed the sheet	Yes
Date of preparation	When the sheet was written, if never reviewed	Yes, if there’s no review date
First issued	When the product’s first SDS came out	No
Print date	Often just when the file was generated or printed	No
Supersedes / previous version	Which earlier version this one replaces	No, but handy for matching copies

A word on “issue date”. Some templates use it for the first-ever version. Others use it for the date this version was released. If it’s the only date on the sheet, it’s probably doing the job of the preparation date. If there’s also a revision date, go with the revision date.

Why is counting from the SDS issue date wrong?

Here’s where workshops get caught out.

Safe Work Australia’s Code of Practice says the manufacturer must review an SDS “at least once every five years from the date of original preparation or the last revision of the SDS.” The latest one counts.

Picture a brake cleaner whose SDS was first issued in 2015 and revised in 2024. Count from 2015 and the sheet looks more than ten years old and badly overdue. Count from 2024 and it’s well inside five years. Use the first-issue date and you’ll flag sheets that are perfectly current, then waste time chasing manufacturers for something you already have.

The print date fails the other way. If it records when somebody downloaded or printed the file, a sheet that hasn’t been reviewed in years can look brand new. That’s the risky mistake, because it hides sheets that genuinely need checking.

Same revision number, newer date? The later date wins

Regulation 330 of the model WHS Regulations gives the manufacturer two separate jobs: review the SDS at least once every five years, and amend it whenever necessary to keep the information correct and current. A review doesn’t always turn up anything to change.

So a manufacturer may review a sheet, find the content still holds, and update only the review date. The regulation asks for the date. The Code recommends a version number, but nothing says it has to change at every review.

That means two copies can share a revision number and still differ. If one says “Revision 4, reviewed 2021” and the other says “Revision 4, reviewed 2026”, keep the 2026 copy. When in doubt, the later review date wins.

Where do you find the SDS review date?

Start with Section 16. It’s the last section of every SDS, headed “Any other relevant information”, and Safe Work Australia says that’s where the review date usually lives. The Code of Practice says Section 16 should include “the date of preparation of the latest revision of the SDS” and, when revisions are made, describe “the changes made to the previous version.” So it’s also where you’ll often find a short summary of what changed.

Then check the header or footer. Many templates repeat a date on every page. That’s handy for a quick glance, but read the label, not just the number. “Print date” in the footer is not the review date.

Make sure you’ve got the whole thing. The Code says SDS pages should be numbered with an indication of the end, such as “Page 1 of 3” or “End of SDS”. A missing last page often means a missing Section 16, and with it the date you need.

If the dates disagree, ask. If Section 16 and the header give different review dates, ask the manufacturer or supplier which is current. Don’t guess.

What should you check on each SDS?

A quick list for every sheet in your register:

• Find the review date. Look in Section 16 first, then the header or footer.
• Read the label. Revision date or date of last review, yes. Print date, no.
• Ignore “first issued” for the five-year clock. It tells you the product’s history, not how current the sheet is.
• Compare copies by date, not just revision number. Same number, later date? Keep the later one.
• Skim the change summary. Section 16 often says what changed since the last version.
• Check the page count. “Page x of y” or “End of SDS” confirms nothing’s missing.
• More than five years since the last review? Ask the manufacturer or supplier for the current sheet. Our guide on how long an SDS is valid covers what to do next.

For the rest of the register routine, see the chemical register audit checklist.

How SupplySafe reads the dates

SupplySafe counts “review due” from the revision date on the sheet, falls back to the issue date only when there’s no revision date, and every screen tells you which date it’s based on. Manufacturers publish their sheets free, and SupplySafe checks each one’s identity, including the revision and dates, without editing it. See how SupplySafe works for the full loop.

Frequently asked questions

What is an SDS revision date?

It's the date the manufacturer last reviewed the safety data sheet. The model WHS Regulations require an SDS to state that date, and the five-year review clock runs from it.

Is the SDS issue date the same as the revision date?

Not always. Some templates use issue date for the first-ever version and others for the date this version was released. If a sheet shows both, go with the revision date.

What if an SDS only shows a date of preparation?

If the sheet has never been reviewed, the model WHS Regulations require it to state the date it was prepared. That's the date to count the five-year review from.

Where do I find the SDS review date?

Safe Work Australia says the review date is usually written in Section 16, Any other relevant information. Many templates also repeat a date in the header or footer, so read the label: a print date is not the review date.

Sources

• Safe Work Australia, Preparing safety data sheets (accessed 14 October 2026)
• Safe Work Australia, Model WHS Regulations (regulation 330 and Schedule 7; accessed 14 October 2026)
• Safe Work Australia, Model Code of Practice: Preparation of safety data sheets for hazardous chemicals (sections 2.1, 2.4 and 3.16; accessed 14 October 2026)
• Safe Work Australia, Model WHS laws (accessed 14 October 2026)
• Queensland Government, Work Health and Safety Regulation 2011 (accessed 14 October 2026)
• WorkSafe Victoria, Safety data sheets (accessed 14 October 2026)