The sheet was out of date

Why the date is in the structure

Section 16, other information, including the date of preparation or last revision. The regulation put it there so a reader can see how current the document is, which means an undated sheet is incomplete on its face.

A reformulation invalidates it

Composition in section 3, hazards in section 2, physical properties in section 9, and the classification behind all of them. Changing an ingredient changes several sections and therefore the sheet.

And so does a change of supplier

A different grade of the same substance can have different impurities and a different classification. A sheet built on one supplier’s material is not automatically right for another’s.

Which makes the sheet a living document

Not a launch artifact. Whoever owns the formula owns the sheet, and the two have to move together or the second one quietly stops describing the first.

Sheets received from suppliers are often the problem

An undated sheet, a sheet with the sixteen headings and little under them, or a sheet with a thin section 15 are all common. Those are the inputs to your own classification, so their quality matters.

Section 15 is the one to read

Regulatory information, where the other regimes get named. A sheet that says nothing there for a product you know is a consumer product or a pesticide has not been checked against anything.

Keep the sheet with the formula version

So that a reformulation visibly reopens it. A sheet filed separately from the formula it describes is a sheet that will be out of date and nobody will notice.

Whoever owns the formula owns the sheet

Naming that person is the whole control. A sheet with no owner drifts out of date invisibly, because nothing about the product changes to announce it.

References