Safety data sheets NZ rules, the 16 sections and Australian SDSs

Safety data sheets NZ rules and the 16 sections

Safety data sheets in NZ are required for hazardous substances supplied for workplace use, with specific exceptions. The business in charge gets the current SDS from the manufacturer, importer or supplier, then keeps that SDS, or condensed key information, where workers and emergency service workers can reach it.

Two sets of rules apply. The EPA's Hazardous Substances (Safety Data Sheets) Notice 2017 sets the SDS rules for importers, manufacturers and suppliers. Regulation 2.11 sets the workplace duties. WorkSafe's guidance explains how those duties work in practice. "MSDS" and "material safety data sheet" are familiar names people still use for an SDS. Whatever the heading says, ask for the current version.

Who prepares the SDS and who must hold it

The EPA says importers and manufacturers prepare the SDS and provide it with the hazardous substance. Suppliers to workplaces provide an SDS and make sure it is complete and correct.

At the workplace end, the duty sits with the PCBU that manages or controls the workplace. Under regulation 2.11(1), it must obtain the current SDS from the manufacturer, importer or supplier:

• when the substance is first supplied for use at that workplace
• when the substance is first supplied after the SDS has been amended.

Under regulation 2.11(2), the first supply after a five-year gap counts as a first supply. You must obtain the current SDS then too.

WorkSafe's guidance says this workplace duty applies regardless of quantity, subject to the exceptions below. It also advises keeping the SDS or key information with your hazardous substances inventory. Use that information to decide your controls. Specialist laboratories should also check regulation 1.11 for the rules that apply to their arrangements.

Making the SDS readily accessible

Regulation 2.11(3) requires the current SDS, or condensed key information such as a product safety card, to be readily accessible to:

• workers in their work areas
• emergency service workers
• anyone else likely to be exposed.

"Readily accessible" is defined in regulation 3 as accessible without difficulty, in hard copy, electronic or another form. Paper isn't compulsory. A tablet in the store works if people can actually use it when something spills.

Workers who travel are covered by regulation 2.11(4). Their SDSs can be held at the principal place of business, as long as the workers can get the key information immediately in an emergency, wherever they are.

When you don't need an SDS

Regulation 2.11(5) switches off the obtaining and access duties for:

• substances in transit
• consumer products at a retailer solely for supply elsewhere, and not to be opened there
• consumer products used only in quantities and in a manner consistent with household use
• anhydrous ammonia in refrigeration plant, unless more than 100 kg is present.

The household-use exception has two parts. A retail-sized bottle of cleaner used at industrial strength across a commercial kitchen doesn't qualify just because of the pack size. Both the quantity and the way you use it have to look like household use.

The exceptions don't remove the safety information duty. Regulation 2.11(6) still requires enough information for safe use, handling and storage to be readily accessible to workers.

Hazardous waste is handled separately. WorkSafe states that "you do not need a safety data sheet for hazardous waste". The waste still has to go on your inventory, be appropriately labelled in containers, and be managed with controls and worker information and training.

How often an SDS must be updated

EPA guidance says an SDS must be revised every five years, and updated sooner when new information becomes available, such as new hazard data or new health and safety information. That makes the five-year mark a review deadline for the person who prepares the sheet. Don't treat it as an expiry date you can wait out.

In practice, check the version or revision date on each SDS in your register, and ask the supplier for the current version when it looks old or the product has changed. The transition to the post-April 2021 requirements ended on 30 April 2025, per the Notice page, so that transition no longer gives extra time.

The 16 sections of an SDS

New Zealand SDSs follow the standard 16-section layout. The EPA's SDS guidance lists them in this order:

The headings above are the EPA's guidance labels. For exact legal wording, read the consolidated Notice.

Can you use an Australian SDS in New Zealand?

Yes, with conditions. The EPA allows alternative compliance using Australian requirements, including Australian state and territory requirements, as long as the NZ-specific information is added. Clause 9 of the Notice covers importers and manufacturers, and clause 10 covers suppliers.

Having 16 sections doesn't make an Australian sheet compliant. Check these NZ particulars in the EPA's SDS guidance:

• In section 1, the product identifier must match the label. The sheet needs recommended uses and restrictions, plus enough contact details for the NZ manufacturer or importer. A website alone isn't enough. If a workplace imports directly from overseas for its own use, and not to resell, the overseas supplier's details can stand in for an NZ importer's.
• The section 1 emergency number must be an NZ freephone number (0800 or 0508, for example). Some hazard classes need 24-hour cover. For other substances, any restricted hours must be stated. The National Poisons Centre can only be listed if the SDS has been submitted to it and accepted.
• Section 2 needs applicable NZ aquatic and terrestrial environmental hazard and precautionary information. The EPA also flags information for flammable liquids Category 4.
• Section 15 needs the HSNO approval number and, where it applies, the group standard title. It also references applicable tolerable exposure limits (TELs) or environmental exposure limits (EELs).

Importers and manufacturers relying on alternative compliance also have a record-keeping duty. Before importing or manufacturing, they create a dated record that identifies the jurisdiction they're following. They keep it for at least two years after supply to New Zealand stops.

If your Australian SDS lacks the required NZ details, ask your supplier for a compliant version.

Where to find an SDS for a product

Go to the manufacturer, importer or supplier of the exact product you bought. Regulation 2.11 names these sources and requires the current SDS. Give them the product name on the label and the supplier, so they send the right sheet. A generic sheet for one of the ingredients, downloaded from somewhere else, doesn't replace it.

The EPA's Chemical Classification and Information Database (CCID) is useful for background. It holds hazard information for single chemicals, including classifications, study summaries and physical properties. You can search it by name, CAS number or approval number. It does not replace the supplier's product-specific SDS. The EPA also says group standard classifications shown in CCID are for information only and aren't legal classifications.

You can read RegAffairs AI's answer on NZ SDS duties for a sourced starting point. For the legal content requirements, use the EPA's consolidated SDS Notice.