COSHH · Mandatory · Construction

Safety Data Sheet Register

The Safety Data Sheet Register collects and organises manufacturer safety data sheets (SDS) for every hazardous substance used on site. SDS documents provide critical information on hazards, first aid measures, handling precautions, PPE requirements, and emergency spill procedures. The register must be accessible to all workers and kept current with the substance inventory.

Last reviewed: 29 March 2026 — This guide reflects UK law as of this date. COSHH Regs 2002 remains current with no amendments enacted as of 29 March 2026. Next scheduled review: 29 March 2027.

What is an SDS	A standardised 16-section document required under the REACH Regulation that communicates the hazards, safe handling, storage, emergency measures, and disposal information for a chemical substance or mixture
REACH obligations	The supplier must provide an SDS free of charge, in English, before or at the time of first supply, and must update it when new information becomes available
16 sections	1. Identification, 2. Hazard identification, 3. Composition, 4. First aid, 5. Fire-fighting, 6. Accidental release, 7. Handling and storage, 8. Exposure controls/PPE, 9. Physical/chemical properties, 10. Stability and reactivity, 11. Toxicological information, 12. Ecological information, 13. Disposal, 14. Transport, 15. Regulatory information, 16. Other information
COSHH link	The SDS is the primary input to the COSHH assessment — it is NOT the assessment itself. A COSHH assessment evaluates the risk of exposure in the specific way the substance is used on this project
Key sections for site use	Section 2 (hazard identification and GHS classification), Section 8 (exposure controls and PPE requirements), Section 14 (transport information)

1. The Role of the SDS in COSHH Compliance

The Safety Data Sheet is the bridge between the substance manufacturer and the employer who must assess and control the risks of using that substance at work. Under COSHH Regulation 6, every employer must carry out a suitable and sufficient assessment of the risk to health from substances hazardous to health used in the workplace. The SDS provides the hazard information, exposure limits, control measures, and emergency procedures that the employer needs to complete that assessment. Without a current SDS, a COSHH assessment cannot be suitable and sufficient.

The REACH Regulation (retained in UK law as UK REACH) requires every supplier of a hazardous substance to provide a Safety Data Sheet to the downstream user. The SDS must be in the official language of the country where the substance is placed on the market — in the UK, this means English. The supplier must provide the SDS free of charge, either in paper or electronic form, and must update it whenever new information about the substance becomes available — for example, revised workplace exposure limits, new toxicological data, or changes to the hazard classification under CLP.

On a construction site, the SDS Register serves as the central repository for all Safety Data Sheets held on the project. It enables the Principal Contractor to confirm that an SDS has been obtained for every hazardous substance before it is used, that the SDS is the current version, and that it has been cross-referenced to the relevant COSHH assessment. The SDS Register works in tandem with the Substance Inventory (Hazmat Register): the Hazmat Register records what substances are on site; the SDS Register holds the detailed safety information for each one.

The current version of the SDS must be held — not the version obtained when the product was first purchased

Suppliers are required under REACH to update the SDS when new information becomes available. This may include revised workplace exposure limits, changes to the hazard classification, new first aid or fire-fighting measures, or updated PPE requirements. An SDS that was obtained three years ago may no longer reflect the current state of knowledge about the substance. The SDS Register must include the SDS issue date and a review mechanism to ensure that the most current version is held. Using an outdated SDS as the basis for a COSHH assessment means the assessment itself may be based on incorrect information.

2. How to Structure an SDS Register

The SDS Register should be structured as a controlled document log that enables the PC to track every Safety Data Sheet on the project, confirm its currency, and cross-reference it to the corresponding Hazmat Register entry and COSHH assessment. The following table sets out the minimum fields that a compliant SDS Register should contain.

Field	Description	Why it matters
Product name	The commercial or trade name of the substance exactly as it appears on the SDS and container label	Ensures consistency between the register, the label, the Hazmat Register, and the COSHH assessment — any discrepancy creates confusion
Supplier	The name of the manufacturer or supplier who issued the SDS	Identifies the responsible party under REACH; required when requesting updated versions or raising queries about the substance
SDS issue date	The date printed on the SDS itself by the supplier — this is the date the supplier issued or revised the document	Determines whether the SDS is the most current version; enables the PC to identify outdated documents during review
Date received	The date the SDS was received on site or by the project team	Provides an audit trail showing that the SDS was obtained before the substance was used; identifies any lag between product arrival and SDS receipt
SDS version number	The version or revision number of the SDS as printed on the document	Enables version control — when a supplier issues a revised SDS, the register must be updated to reflect the new version and the old version archived
Location of SDS file	Where the physical or digital copy of the SDS is held — e.g. site office COSHH folder, digital system reference, or cloud storage location	Ensures that any person who needs to access the SDS — worker, supervisor, first aider, emergency responder — knows where to find it
Hazmat Register reference	The corresponding entry number or reference in the Substance Inventory / Hazmat Register	Cross-links the two registers so that the summary information in the Hazmat Register can be traced to the full SDS, and vice versa
COSHH assessment reference	The reference number of the COSHH assessment that has been completed for this substance	Confirms that the SDS has been translated into a COSHH assessment as required by Regulation 6; any SDS without a corresponding COSHH assessment represents a gap in compliance
Next review due	The date by which the SDS should be reviewed to confirm it is still the current version from the supplier	Drives the review cycle — without a review date, outdated SDS documents will accumulate unnoticed. A 12-month review cycle is typical for construction projects

Section 4 (First Aid Measures) must be provided to site first aiders

Section 4 of the SDS contains the specific first aid measures for the substance — what to do in the event of skin contact, eye contact, inhalation, or ingestion. This information must be provided to site first aiders and made available at the point of use. A first aider who does not have access to substance-specific first aid information may administer incorrect treatment — for example, inducing vomiting for a substance where vomiting is contra-indicated, or flushing with water where a different treatment is specified. The SDS Register should facilitate rapid access to this critical section.

3. Common Mistakes

Not obtaining the SDS before the product is used on site

The SDS must be obtained before the substance is used, not after. REACH requires the supplier to provide the SDS before or at the time of first supply. If a subcontractor brings a product to site and starts using it without an SDS being held in the register, the COSHH assessment for that substance cannot have been completed and the workers using it are unprotected. The PC’s delivery acceptance and site induction procedures should include a check that the SDS has been received and registered before any new substance is permitted on site.

Holding outdated Safety Data Sheets

An SDS is not a one-time document. Suppliers revise SDS when new hazard information emerges, when workplace exposure limits are updated, when hazard classifications change under CLP, or when new regulatory requirements come into force. An SDS that was obtained at the start of a two-year project may have been superseded by the time the substance is still being used in year two. The SDS Register must include a review date for each entry, and the PC must have a process for checking with suppliers whether updated versions are available. Using an outdated SDS as the basis for a COSHH assessment undermines the assessment.

Not making SDS accessible to workers who use the substances

An SDS that is filed in a locked cabinet in the site office is compliant on paper but useless in practice. Workers who handle hazardous substances need access to the safety information in the SDS — particularly the sections on safe handling (Section 7), exposure controls and PPE (Section 8), and first aid measures (Section 4). The SDS should be available at the point of use, not only in the site office. Digital access via tablet or phone, or laminated summary cards derived from the SDS, are practical solutions for site-based access.

Treating the SDS as the COSHH assessment

This is one of the most widespread compliance failures. The SDS describes the hazards of the substance in general terms. The COSHH assessment evaluates the risk of exposure in the specific way the substance is used on this project — the task, the duration, the frequency, the environment, and the workers involved. Holding an SDS does not satisfy COSHH Regulation 6. The SDS is an input to the COSHH assessment, not a substitute for it. Every substance on the SDS Register must have a corresponding COSHH assessment that addresses the actual conditions of use on the project.

Not providing Section 4 (First Aid Measures) to first aiders

Section 4 of the SDS contains substance-specific first aid instructions for skin contact, eye contact, inhalation, and ingestion. If site first aiders do not have access to this information, they cannot provide appropriate treatment. Some substances require specific antidotes or treatments that differ from standard first aid protocols. For example, hydrofluoric acid burns require calcium gluconate gel, not standard burn treatment. Failing to make Section 4 available to first aiders and at the point of use creates a risk that incorrect first aid will be administered, potentially worsening the injury.

4. Related Documents

The SDS Register works alongside several other compliance documents on a construction project. The following table describes the relationship between the SDS Register and each related document.

Document	Relationship
C1 — General Site Induction	The site induction should inform all workers of the location of the SDS Register and how to access Safety Data Sheets for substances they will be working with. The induction should also explain the requirement to obtain an SDS before any new substance is brought to site, and the process for notifying the PC.
C13 — Substance Inventory / Hazmat Register	The Hazmat Register and the SDS Register are companion documents. The Hazmat Register records what substances are on site, their classifications, storage locations, and quantities. The SDS Register holds the detailed 16-section Safety Data Sheets for each substance. Every entry in the Hazmat Register must cross-reference the corresponding SDS, and every SDS in the register must cross-reference the Hazmat Register entry.
F11 — Fire Risk Assessment	The Fire Risk Assessment must consider the flammable substances present on site. Section 2 (Hazard Identification), Section 5 (Fire-fighting Measures), and Section 9 (Physical and Chemical Properties — including flash point and flammability) of the SDS provide the information needed to assess fire risk from chemical substances. The SDS Register enables the fire risk assessor to locate and review this information for every substance on site.
F14 — Emergency Plan	The site Emergency Plan must include procedures for chemical spills, fires involving hazardous substances, and exposure incidents. Section 4 (First Aid), Section 5 (Fire-fighting), and Section 6 (Accidental Release) of the SDS provide the substance-specific information needed for emergency response. The Emergency Plan should reference the SDS Register and confirm that emergency responders know how to access it.

5. Frequently Asked Questions

Are suppliers legally required to provide a Safety Data Sheet?▾

Yes. Under the REACH Regulation (retained in UK law as UK REACH), suppliers of substances or mixtures classified as hazardous under CLP must provide a Safety Data Sheet to the downstream user free of charge, in English, before or at the time of first supply. The SDS must comply with the standardised 16-section format set out in Annex II of REACH. The supplier must also provide an updated SDS when new information becomes available — for example, revised exposure limits, new hazard data, or changes to the classification. Failure to provide an SDS is a breach of the supplier’s obligations under REACH and should be reported to the HSE.

What is an extended Safety Data Sheet (eSDS)?▾

An extended Safety Data Sheet (eSDS) is an SDS that includes an Annex containing one or more Exposure Scenarios. Exposure Scenarios are required under REACH for substances registered at 10 tonnes or more per year. Each Exposure Scenario describes a specific use of the substance, the conditions under which it can be used safely (including operational conditions and risk management measures), and the resulting exposure levels. If the way the substance is used on site falls outside the conditions described in the Exposure Scenario, the downstream user must either adapt their use to fall within the described conditions, notify the supplier so that a new Exposure Scenario can be prepared, or carry out their own chemical safety assessment. In practice, for construction site use, the eSDS provides more detailed and use-specific information than a standard SDS.

Can a digital photograph of the SDS replace a paper copy?▾

A digital copy of the SDS — whether a photograph, a scanned PDF, or a supplier-provided electronic version — is acceptable provided it is legible, complete (all 16 sections), and the current version. The key requirements are accessibility and currency, not format. A legible digital copy stored on a tablet, phone, or cloud-based system that can be accessed at the point of use is in many ways more practical than a paper copy in a ring binder in the site office. However, the SDS must be accessible even if the digital system is unavailable — for example, if the site loses internet connectivity during an emergency. A contingency arrangement (such as a printed backup set in the first aid room) is advisable.

What should be done if a supplier refuses to provide an SDS?▾

If a supplier refuses to provide a Safety Data Sheet for a hazardous substance, the substance must not be used on site. The supplier is in breach of their obligations under UK REACH, and the employer cannot discharge their duty under COSHH Regulation 6 to carry out a suitable and sufficient assessment without the information contained in the SDS. The PC should inform the supplier in writing that the provision of an SDS is a legal requirement under REACH, and that the substance will not be permitted on site until an SDS is provided. If the supplier continues to refuse, the matter should be reported to the HSE, which is the enforcing authority for REACH in the UK. An alternative product from a compliant supplier should be sourced.

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