Part F — Hazardous Substances
SDS Review Checklist
Owner
HSE Manager / Document Controller
Review / trigger
Annual review; update on legal, authority, project or client change
Checkpoints
88
| # | Area | Checkpoint / Requirement | Evidence / Acceptance Criteria | Responsible | Frequency |
|---|---|---|---|---|---|
| 1 | 1. SDS Collection and Source Verification | SDS obtained directly from manufacturer or authorized supplier at time of first purchase | Procurement record shows SDS attached to purchase order | Procurement Coordinator | Per new chemical |
| 2 | 1. SDS Collection and Source Verification | SDS authenticity verified against supplier letterhead and product batch details | Cross-check of SDS header details against delivery note | HSE Officer | Per new chemical |
| 3 | 1. SDS Collection and Source Verification | SDS requested in both English and Arabic from supplier at point of order | Supplier correspondence requesting bilingual SDS retained | Procurement Coordinator | Per new chemical |
| 4 | 1. SDS Collection and Source Verification | SDS for locally reformulated or blended products obtained from local manufacturer | Local manufacturer SDS on file matching product label | HSE Officer | Per new chemical |
| 5 | 2. SDS Currency and Version Control | SDS revision date checked and confirmed not older than 3 years or per GSO 1270 update cycle | SDS revision date log reviewed against 3-year threshold | HSE Officer | Quarterly |
| 6 | 2. SDS Currency and Version Control | Superseded SDS versions removed from active files and archived separately | Archive folder review confirms no obsolete SDS in active binder | HSE Officer | Quarterly |
| 7 | 2. SDS Currency and Version Control | Version control log maintained tracking SDS updates per chemical | Version control register with revision numbers and dates | HSE Officer | Quarterly |
| 8 | 2. SDS Currency and Version Control | Supplier notified request for updated SDS when reformulation or regulatory change occurs | Correspondence log requesting updated SDS following notification | Procurement Coordinator | As required |
| 9 | 2. SDS Currency and Version Control | Annual SDS currency review completed for entire chemical inventory | Annual review report signed by HSE Manager | HSE Manager | Annually |
| 10 | 3. Arabic Translation Compliance | Arabic-language SDS available for every chemical alongside English version | Bilingual SDS file check for 100% of inventory items | HSE Officer | Quarterly |
| 11 | 3. Arabic Translation Compliance | Arabic translation verified for technical accuracy by qualified translator or certified source | Translation verification certificate or supplier confirmation on file | HSE Manager | Per new chemical |
| 12 | 3. Arabic Translation Compliance | Arabic SDS content matches English version in hazard classification and section sequence | Side-by-side comparison checklist completed for sample SDS | HSE Officer | Quarterly |
| 13 | 3. Arabic Translation Compliance | Machine-translated SDS flagged and replaced with certified translation where accuracy uncertain | Flagged item log with replacement tracking | HSE Officer | As required |
| 14 | 4. SDS Technical Content Review - Hazard Identification | Section 2 hazard classification reviewed against GHS categories and pictograms | Reviewer checklist confirming classification consistency | HSE Officer | Per new chemical |
| 15 | 4. SDS Technical Content Review - Hazard Identification | Section 3 composition/ingredient information checked for CAS numbers and concentration ranges | Ingredient data cross-checked against product technical datasheet | HSE Officer | Per new chemical |
| 16 | 4. SDS Technical Content Review - Hazard Identification | Section 4 first-aid measures reviewed and cross-referenced with site first aid provisions | First aid measures matched to on-site first aid kit contents | HSE Officer | Per new chemical |
| 17 | 4. SDS Technical Content Review - Hazard Identification | Section 7 handling and storage requirements reviewed against actual site storage conditions | Storage requirement comparison checklist completed | HSE Officer | Per new chemical |
| 18 | 4. SDS Technical Content Review - Hazard Identification | Section 8 exposure controls/PPE requirements reviewed against issued PPE for task | PPE requirement cross-check against issued PPE register | HSE Officer | Per new chemical |
| 19 | 5. SDS Technical Content Review - Emergency and Exposure Data | Section 6 accidental release measures reviewed and incorporated into spill response procedure | Spill procedure updated to reflect SDS-specific guidance | HSE Officer | Per new chemical |
| 20 | 5. SDS Technical Content Review - Emergency and Exposure Data | Section 9 physical/chemical properties checked for flashpoint and flammability data relevant to storage class | Storage classification cross-checked against flashpoint data | HSE Officer | Per new chemical |
| 21 | 5. SDS Technical Content Review - Emergency and Exposure Data | Section 11 toxicological information reviewed for occupational exposure limit values applicable in UAE | OEL values compared against OSHAD/MOHRE reference limits | HSE Officer | Per new chemical |
| 22 | 5. SDS Technical Content Review - Emergency and Exposure Data | Section 14 transport information checked for compliance with UAE dangerous goods transport rules | Transport classification matched to delivery vehicle placarding | HSE Officer | Per new chemical |
| 23 | 6. Integration into Site Risk Assessments and Method Statements | Chemical risk assessment updated to reflect current SDS hazard data before task commencement | Risk assessment revision log referencing SDS version | HSE Officer | Per new chemical |
| 24 | 6. Integration into Site Risk Assessments and Method Statements | Method statement for chemical-related tasks cross-references applicable SDS number | Method statement document includes SDS reference field | HSE Officer | Per new chemical |
| 25 | 6. Integration into Site Risk Assessments and Method Statements | Toolbox talks incorporate key SDS hazard points before task start | Toolbox talk record referencing SDS content covered | Site Supervisor | Daily |
| 26 | 6. Integration into Site Risk Assessments and Method Statements | Changes in SDS content trigger re-assessment of related risk assessments and permits | Change log linking SDS update to risk assessment revision | HSE Manager | As required |
| 27 | 7. Accessibility and Communication of SDS Information | SDS displayed or accessible at point of chemical use, not only central store | Work area walkthrough confirms SDS access at usage point | HSE Officer | Weekly |
| 28 | 7. Accessibility and Communication of SDS Information | Workers demonstrate understanding of relevant SDS content for chemicals they handle | Verbal competency check/quiz record for sampled workers | HSE Officer | Quarterly |
| 29 | 7. Accessibility and Communication of SDS Information | Mobile/digital SDS access tool tested for functionality on-site including offline access | Digital SDS app functionality test log | HSE Officer | Quarterly |
| 30 | 7. Accessibility and Communication of SDS Information | Emergency responders and Civil Defence provided access to critical SDS during mobilization drills | Drill record confirming SDS provided to responding team | HSE Manager | Annually |
| 31 | 8. SDS Review Governance and Record Keeping | Designated competent person assigned responsibility for SDS review and update cycle | Appointment letter/role assignment on file | HSE Manager | Annually |
| 32 | 8. SDS Review Governance and Record Keeping | SDS review log maintained recording reviewer, date, findings and actions | Review log entries complete for all reviewed SDS | HSE Officer | Quarterly |
| 33 | 8. SDS Review Governance and Record Keeping | Non-conforming or incomplete SDS escalated to supplier with corrective request | Escalation correspondence and supplier response on file | Procurement Coordinator | As required |
| 34 | 8. SDS Review Governance and Record Keeping | SDS records retained for minimum retention period per company document control procedure | Document control register showing retention compliance | HSE Officer | Annually |
| 35 | 9. Regulatory Alignment and External Verification | SDS review process aligned with OSHAD-SF Mechanism and Federal Decree-Law No. 20 of 2020 requirements | Compliance mapping document cross-referenced to legislation | HSE Manager | Annually |
| 36 | 9. Regulatory Alignment and External Verification | SDS compliance verified against GSO 1270 GHS classification and labelling standard | Compliance verification checklist against GSO 1270 clauses | HSE Officer | Annually |
| 37 | 9. Regulatory Alignment and External Verification | Third-party or client HSE audit findings on SDS management tracked to closure | Audit finding tracker with closure evidence | HSE Manager | Per audit |
| 38 | 9. Regulatory Alignment and External Verification | SDS review procedure re-validated following any change in UAE chemical regulation | Procedure revision record linked to regulatory bulletin | HSE Manager | As required |
| 39 | 1. SDS Collection and Source Verification | SDS for imported chemicals accompanied by import compliance documentation confirming UAE registration | Import documentation cross-checked with MOCCAE/customs clearance | Procurement Coordinator | Per new chemical |
| 40 | 1. SDS Collection and Source Verification | Duplicate or conflicting SDS versions from multiple suppliers for same product reconciled to single approved version | Reconciliation record identifying approved master SDS | HSE Officer | Per new chemical |
| 41 | 2. SDS Currency and Version Control | SDS update triggers include change in classification, new toxicological data or regulatory amendment | Trigger event log linked to SDS revision history | HSE Officer | As required |
| 42 | 2. SDS Currency and Version Control | Reminder system (calendar/register) in place to flag upcoming SDS review due dates | Reminder log/tracker showing upcoming and completed reviews | HSE Officer | Monthly |
| 43 | 3. Arabic Translation Compliance | Bilingual SDS summary card prepared for high-risk chemicals for quick worker reference | Sample bilingual summary card reviewed for accuracy | HSE Officer | Per new chemical |
| 44 | 3. Arabic Translation Compliance | Language competency of workforce assessed to determine additional pictogram/visual aid needs beyond text SDS | Workforce language survey results retained | HSE Manager | Annually |
| 45 | 4. SDS Technical Content Review - Hazard Identification | Section 1 identification data (product identifier, supplier contact, emergency number) verified for accuracy | Identification section cross-checked against label and supplier records | HSE Officer | Per new chemical |
| 46 | 4. SDS Technical Content Review - Hazard Identification | Section 5 firefighting measures reviewed and communicated to site fire warden/emergency team | Fire warden briefing record referencing SDS firefighting guidance | HSE Officer | Per new chemical |
| 47 | 4. SDS Technical Content Review - Hazard Identification | Reviewed SDS content signed off by HSE Manager before chemical released for site use | Sign-off form attached to SDS file prior to release | HSE Manager | Per new chemical |
| 48 | 5. SDS Technical Content Review - Emergency and Exposure Data | Section 10 stability and reactivity data reviewed for compatibility with adjacent stored chemicals | Reactivity compatibility check cross-referenced to storage segregation plan | HSE Officer | Per new chemical |
| 49 | 5. SDS Technical Content Review - Emergency and Exposure Data | Section 12 ecological information reviewed to inform spill environmental protection measures | Environmental protection measures updated per SDS ecological data | HSE Officer | Per new chemical |
| 50 | 5. SDS Technical Content Review - Emergency and Exposure Data | Section 13 disposal considerations reviewed and aligned with EPD-approved disposal method | Disposal method cross-checked against SDS Section 13 guidance | HSE Officer | Per new chemical |
| 51 | 5. SDS Technical Content Review - Emergency and Exposure Data | Section 15 regulatory information cross-checked against current UAE federal and local chemical regulations | Regulatory cross-check record retained with SDS file | HSE Manager | Per new chemical |
| 52 | 6. Integration into Site Risk Assessments and Method Statements | Permit-to-work for hot work near chemical storage cross-references SDS flammability data | Permit-to-work form includes SDS flashpoint reference field | HSE Officer | Per permit |
| 53 | 6. Integration into Site Risk Assessments and Method Statements | Emergency response plan updated to reflect aggregated hazard profile from reviewed SDS set | Emergency response plan revision log referencing SDS review outcomes | HSE Manager | Annually |
| 54 | 7. Accessibility and Communication of SDS Information | SDS awareness poster/summary displayed in workers' primary language at accommodation and site notice boards | Poster placement verified during site and camp walkthrough | HSE Officer | Monthly |
| 55 | 7. Accessibility and Communication of SDS Information | Feedback mechanism available for workers to report SDS translation errors or access issues | Feedback log with logged issues and resolution status | HSE Officer | Quarterly |
| 56 | 8. SDS Review Governance and Record Keeping | SDS review checklist itself periodically reviewed and updated to reflect regulatory changes | Checklist revision history log | HSE Manager | Annually |
| 57 | 8. SDS Review Governance and Record Keeping | Independent internal audit of SDS review process conducted to verify governance effectiveness | Internal audit report with findings and corrective actions | HSE Manager | Annually |
| 58 | 9. Regulatory Alignment and External Verification | SDS review process benchmarked against Abu Dhabi OSHAD and Dubai Municipality chemical safety codes where applicable | Benchmarking report referencing applicable jurisdictional code | HSE Manager | Annually |
| 59 | 9. Regulatory Alignment and External Verification | Corrective actions from SDS-related regulatory non-conformances verified as effective in follow-up review | Follow-up verification report confirming effectiveness | HSE Manager | Per non-conformance |
| 60 | 10. SDS Quality Assurance Sampling | Random sampling of SDS files conducted quarterly to verify accuracy and completeness across inventory | Sampling audit report covering minimum 10% of inventory | HSE Officer | Quarterly |
| 61 | 10. SDS Quality Assurance Sampling | Sampling results trended over time to identify recurring supplier or translation quality issues | Trend analysis report presented to HSE Manager | HSE Manager | Quarterly |
| 62 | 10. SDS Quality Assurance Sampling | Poor-performing suppliers on SDS quality flagged for procurement review or replacement | Supplier performance review record with SDS quality criterion | Procurement Coordinator | Annually |
| 63 | 10. SDS Quality Assurance Sampling | Lessons learned from SDS quality issues shared across project sites within the organization | Lessons-learned bulletin circulated to multi-site HSE team | HSE Manager | As required |
| 64 | 11. Project Handover and Close-out SDS Records | Complete SDS register and files handed over to facilities management team at project close-out | Handover certificate listing transferred SDS documentation | HSE Manager | Per project close-out |
| 65 | 11. Project Handover and Close-out SDS Records | Archived SDS records retained per project document retention schedule after demobilization | Archive storage confirmation with retention period noted | HSE Officer | Per project close-out |
| 66 | 11. Project Handover and Close-out SDS Records | Outstanding SDS review actions closed out or formally transferred before final handover | Close-out action tracker showing zero open items or documented transfer | HSE Manager | Per project close-out |
| 67 | 1. SDS Collection and Source Verification | SDS collection tracked in procurement onboarding workflow before chemical delivery accepted | Onboarding workflow record showing SDS collection step completed | Procurement Coordinator | Per new chemical |
| 68 | 2. SDS Currency and Version Control | SDS database cross-checked against manufacturer website/portal for latest published version | Cross-check log with manufacturer portal screenshot/reference | HSE Officer | Quarterly |
| 69 | 2. SDS Currency and Version Control | Discontinued products' SDS retained for historical exposure record purposes even after phase-out | Discontinued product archive log with retention justification | HSE Officer | Annually |
| 70 | 3. Arabic Translation Compliance | Translation service provider credentials verified for technical/chemical translation competence | Translator credential file retained by HSE department | HSE Manager | Per new chemical |
| 71 | 4. SDS Technical Content Review - Hazard Identification | SDS reviewed for consistency with product technical data sheet application instructions | Cross-comparison record between SDS and technical data sheet | HSE Officer | Per new chemical |
| 72 | 5. SDS Technical Content Review - Emergency and Exposure Data | SDS exposure limit values reconciled with ventilation and engineering control design for enclosed work areas | Engineering control design review referencing SDS exposure limits | HSE Officer | Per new chemical |
| 73 | 6. Integration into Site Risk Assessments and Method Statements | COSHH-style chemical risk matrix updated whenever SDS review identifies revised hazard rating | Risk matrix revision log tied to SDS review date | HSE Officer | As required |
| 74 | 7. Accessibility and Communication of SDS Information | New joiners provided SDS orientation covering location and interpretation during site induction | Induction record confirming SDS orientation topic covered | HSE Officer | Per new starter |
| 75 | 8. SDS Review Governance and Record Keeping | SDS review KPI (percentage current, percentage bilingual) reported to project management monthly | Monthly KPI dashboard/report retained | HSE Manager | Monthly |
| 76 | 9. Regulatory Alignment and External Verification | SDS review programme includes verification of compliance with UAE Fire and Life Safety Code for stored quantities referenced in SDS | Fire and Life Safety Code cross-check record | HSE Manager | Annually |
| 77 | 10. SDS Quality Assurance Sampling | Discrepancies found during SDS sampling logged as non-conformance in HSE management system | Non-conformance report generated from sampling findings | HSE Officer | Quarterly |
| 78 | 11. Project Handover and Close-out SDS Records | SDS review process performance summarized in project close-out HSE report for lessons learned | Close-out HSE report including SDS review performance summary | HSE Manager | Per project close-out |
| 79 | 11. Project Handover and Close-out SDS Records | Digital SDS repository access credentials transferred to receiving facilities management team | Access credential transfer confirmation record | HSE Manager | Per project close-out |
| 80 | 10. SDS Quality Assurance Sampling | SDS sampling audit scope includes both English and Arabic versions equally | Sampling audit scope document confirming bilingual coverage | HSE Officer | Quarterly |
| 81 | 9. Regulatory Alignment and External Verification | SDS review team attends periodic UAE regulatory update briefings (MOHRE/OSHAD/MOCCAE) to stay current | Briefing attendance record for SDS review personnel | HSE Manager | Annually |
| 82 | 8. SDS Review Governance and Record Keeping | Electronic SDS management system access restricted to authorized HSE personnel with audit trail enabled | System access control list and audit trail export | HSE Manager | Quarterly |
| 83 | 7. Accessibility and Communication of SDS Information | SDS content summarized into simplified pictogram-based cards for low-literacy workers | Simplified card samples reviewed for clarity | HSE Officer | Per new chemical |
| 84 | 6. Integration into Site Risk Assessments and Method Statements | Subcontractor method statements independently verified to reference correct and current SDS | Method statement review log confirming SDS reference accuracy | HSE Officer | Per submission |
| 85 | 5. SDS Technical Content Review - Emergency and Exposure Data | SDS reviewed to confirm consistency of hazard statements with product label wording | Label-to-SDS hazard statement comparison record | HSE Officer | Per new chemical |
| 86 | 4. SDS Technical Content Review - Hazard Identification | Section 16 other information (revision indicators, abbreviations key) reviewed to confirm currency markers are clear | Section 16 review note confirming revision indicator present | HSE Officer | Per new chemical |
| 87 | 3. Arabic Translation Compliance | Random sample of Arabic SDS translations independently back-translated to confirm technical fidelity | Back-translation verification report for sampled SDS | HSE Manager | Annually |
| 88 | 2. SDS Currency and Version Control | SDS currency status reported as a standing agenda item in monthly HSE committee meeting | HSE committee meeting minutes including SDS currency status | HSE Manager | Monthly |
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