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Is one SDS enough for different brands of paint?

Q: Our maintenance department has a lot of different brands of aerosol touch-up paint that it uses when repairing equipment. All the cans are stored appropriately. Are we required to have one SDS for every brand and colour or can we just have one and use it for all like products?

A: Under the Work Health and Safety Regulations 2012 (SA)(Regulations), a person conducting a business or undertaking (PCBU) is only required to obtain and make available safety data sheets for hazardous chemicals in the workplace (r 344). There is otherwise no general requirement for a PCBU to have safety data sheets for other materials in the workplace. The SDS needs to be readily accessible to a person at the workplace if they are likely to be affected by the hazardous chemical or if they request the SDS.

A hazardous chemical is defined in r 5 of the Regulations by reference to the hazard classes in the third revised edition of the Globally Harmonised System of Classification and Labelling of Chemicals (GHS), published by the United Nations as modified by Schedule 6 of the Regulation.

As such, you will need an SDS for any chemical in the workplace which is defined as a hazardous chemical in accordance with the definition in section 5 of the Regulations. Any chemical in the workplace which falls outside this definition will not require an SDS.

We are of the view that aerosol touch up paint is a hazardous chemical.

Where relevant, an SDS should be obtained for each brand as there is a requirement for an SDS to specify a product identifier and identity for the chemical, as well as composition and information on ingredients, which may vary between brands.


There is a general exception from providing an SDS at all if the chemical is a consumer product that is likely to be used in the same quantity and manner as a household product.

If this exception deals with any chemicals you have in your offices, you only need to ensure that “sufficient information about the safe use, handling and storage of the chemical is readily accessible” to staff and emergency workers.

Please note: The answer is correct at the time of publishing. Be aware that laws may change over time. Refer to Chemical safety for current advice.

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