Over the last few years HSE held discussions with some solder suppliers about provision of information and appropriate labelling within the meaning of the Chemicals (Hazard Information and Packaging for Supply) Regulations (CHIP). However, legal opinions varied on whether rosin cored solder is an ‘article’, a ‘substance’ or a ‘preparation’ within the meaning of the legislation, and thus whether CHIP applies to rosin cored solder, and consequently a Safety Data Sheet and labelling is required under CHIP.

Irrespective of whether CHIP applies, it is HSE view that there is an underlying requirement on suppliers within section 6 of the Health & Safety at Work etc Act 1974 to ensure users are provided with adequate information. 

However there was no consensus on the information to be provided or the format in which it should be provided.  In an attempt to resolve this impasse HSE invited all known suppliers of rosin cored solder to a workshop to discuss the issues. At the workshop held in September 2006 there was broad consensus amongst those attending that suppliers would welcome an agreed set of information to be supplied with rosin cored solder to ensure a ‘level playing field’. Additionally the opinion of those attending was that users would welcome the information in a common format, and that the format best understood within industry was a safety datasheet (SDS).

A small working group, drawn from those attending the seminar and led by the HSE, was tasked with developing an example SDS for rosin cored solder. The example SDS available at the link below is the result.

This working group was comprised of:
Sarah Haynes, HSE
Chris Packham, BOHS and proprietor of EnviroDerm Services
Dr Rosie Guthrie, Senior Regulatory Scientist, Henkel Technologies
Desmond Waight, Director of DanGoods Training and Consultancy Ltd

IMPORTANT NOTES:

1. The HSE was a ‘participant’ in the industry working group that developed the example SDS.
2. HSE participated in the working group in good faith, but does not authorise or approve the particular example. HSE has no expertise on, or locus for, environmental matters.
3. There is uncertainty about the application of CHIP to rosin cored solder, and consequently while suppliers should provide information about the hazards, it may not be necessary to do so in the form of an SDS. It is up to the suppliers of rosin cored solder to ensure the information they supply meets the legal requirements.
4. The purpose of this particular example SDS is to encourage suppliers of rosin cored solder to provide consistent information about the hazards in a common format.
5. The SDS has not been updated to meet Regulation (EC) No 1907/2006 requirements and guidance. At this time all that would be needed is to swap the order of Sections 2 and 3  (though REACH does not mandate the order) and to provide an email address of the competent person who is responsible for the compilation of the SDS.
6. CHCS is making this available in the interests of better hazard communication, but was NOT represented in the working group.
7. CHCS and its Officers can accept no liability for any use of the example.
8. Use of this example as a basis for a SDS for any specific product should be made only if the above is fully accepted by the intended user.  

To access the example SDS click here.