Direct answer: Create a reliable composition section for substances or mixtures.
Identify whether the product is a substance or mixture
The required composition presentation begins with product type. A pure substance record and a formulated mixture should not share an interchangeable table.
Use supplier-grade records
CAS identity alone does not capture concentration, stabilizers, impurities or the exact commercial raw material. Link each formulation line to its current supplier evidence.
Control concentration values and ranges
Store exact internal values separately from published values or ranges. Any range should remain useful for hazard communication and consistent with the classification basis.
Document trade-secret handling
A withheld identity or concentration requires a reviewed legal basis and controlled disclosure output. Do not replace sensitive fields with improvised placeholders.
Connect Section 3 back to classification
Every ingredient driving a hazard decision should have traceable classification evidence. A changed raw-material record should trigger review of the finished product.
Practical example
A raw material named ‘surfactant blend’ contains several components. The formulator records the supplied blend as used, links its SDS, and separately maps reportable constituents rather than assigning the blend name a guessed CAS number.
Release checklist
- Set product type
- Link each raw material to supplier evidence
- Store exact and published concentrations separately
- Review disclosure and trade-secret basis
- Trigger reclassification when decisive inputs change
Common mistakes
- Treating a trade name as a pure substance
- Publishing exact formulation by accident
- Using a CAS lookup as a substitute for supplier composition
Frequently asked questions
Must every ingredient be listed?
Disclosure depends on the product and applicable requirements. Make a documented decision rather than assuming all or none.
Can concentration ranges be used?
Ranges may be used in appropriate circumstances, but they must support accurate hazard communication and the applicable disclosure basis.
What if the supplier only gives a broad range?
Preserve that uncertainty, request clarification where material, and avoid calculations that assume an unsupported exact value.
Does Section 3 determine classification by itself?
No. It supplies key inputs, but product properties, tests and applicable mixture methods may also matter.
Primary sources
- OSHA Hazard Communication Standard, 29 CFR 1910.1200
- OSHA Hazard Communication overview
- OSHA Appendix D: Safety Data Sheets
Review notice: EXPERT US REGULATORY REVIEW REQUIRED BEFORE INDEXING OR COMMERCIAL RELIANCE.