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Safety Data Sheets (SDS) - Frequently Asked Questions

Question
What does the legislation require concerning the SDS Compiler Competence?

Answer
The European Union legislation concerning compilation of Safety Data Sheets (SDSs) requires that the person compiling an SDS be "competent" (reference: REACH Regulation 1907/2006 Annex II Requirements for the compilation of Safety Data Sheets, para 0.2.3 of the introductory comments). The Regulation then says "Suppliers of substances and mixtures shall ensure that such competent persons have received appropriate training, including refresher training."

There is no further official EU requirement or guidance as to what constitutes appropriate training/refresher training. There is no EU or UK Government controlled, or approved, examination system with a set pass level and certification.

The requirement means that training should be given, or if applicable suitably refreshed, BEFORE a person is required by the employer to write or amend a Safety Data Sheet.

CHCS runs modular training for SDS writers, and the concept here is that the intended SDS compiler need only attend those modules of relevance - e.g. if the person is a toxicologist then there is no need to attend Module 5 – Basic Toxicology. Also it may be that the company has a person responsible for certain aspects of the tasks involved in order to compile an SDS, e.g. a Dangerous Goods Safety Adviser (DGSA) providing the data for Section 14 may obviate the need for the SDS compiler to attend Module 8, Classification for Transport, and Module 10, Transport Labelling and Documentation.

The full list of current training modules can be found on the Training page of this website.

CHCS normally offers each Module at least once a year. Where there is sufficient demand, modules may be offered more frequently. If you would like to attend a Module that is not currently advertised, or for which is not due to be run for some time, please do get in touch with the office to let us know of your interest. Where there is sufficient interest, we will look at running additional Modules when feasible.

If you want to attend all of the modules, it might mean that it could take up to a year to become "competent" enough to undertake SDS compilation. For that reason you might want to consider running some of the Modules in-house or utilising a suitable CHCS listed consultant to carry out initial training to an adequate level to meet the legal requirements, with later attendance at some of the Modules to supplement, reinforce, extend or refresh this initial competence.

Question
Do the REACH regulations allow us to publish Safety Data Sheet updates on the internet and inform our customers that they can access them rather than having to supply hard copies?

Answer
REACH Regulation Article 31(8) says that you shall 'provide' a safety data sheet free of charge, on paper or electronically to the recipient. The word ‘provide’ implies a positive duty on behalf of the supplier to actively send the Safety Data Sheet to the customer. Simply posting this information on your website and passively allowing users to find the Safety Data Sheet is 'making available' the information and not 'providing' it and therefore you would not be complying with REACH.

Some suppliers have questioned whether it is ok to send a link to a Safety Data Sheet on a website by email instead of attaching, for example, a PDF document. Sending a link to your general website that would require customers to then search for and download this document would not be considered an acceptable way of providing this information.

There is an ongoing discussion over whether it is acceptable to provide a direct link in an email to some or all of the Safety Data Sheet. This discussion is particularly relevant where extended Safety Data Sheets with many exposure scenarios need to be provided. In such a case it is likely that there would be some conditions to providing information in this way. For example, the supplier would need to ensure that the URL of the Safety data Sheet did not change for a reasonable length of time in case their website was redeveloped, that recipients and perhaps Member State Competent Authorities might have to agree this in advance, and so on.

Question
Do I have to supply overseas customers with SDSs in their language?

Answer
For supply within the EU/EEA, REACH Article 31(5) says that the SDS shall be supplied in an official language of the Member State(s) where the product is placed on the market, unless the MS provides otherwise.

For supply outside of the EU/EEA, Article 17 of the PIC Regulation requires that a REACH-compliant SDS should be given to the non-EU/EEA customer, and that, far as practicable, this should be given in the official languages, or in one or more of the principal languages, of the country of destination or of the area of intended use.

Question
Whose name and address should appear in section 1 of the SDS?

Answer
The name and address should be that of the supplier placing the substance or mixture on the EU/EEA market whether that is the manufacturer, importer, only representative, downstream user or distributor.

If the supplier is outside the EU/EEA (note: even if in Switzerland) then an EU/EEA name & address is mandatory. In addition to the name and address of the EU/EEA supplier, details of the non-EU/EEA manufacturer or formulator can be optionally provided.

Question
If a mixture has been classified as non-hazardous does that mean that I don’t need to produce a Safety Data Sheet?

Answer
It’s not necessarily true that non-hazardous chemicals are not regulated by the REACH Regulation. Article 31(3) of REACH sets out requirements for Safety Data Sheets to be prepared and provided on request to customers for mixtures that are not classified as hazardous but which contain

  • hazardous substance(s) classified in respect of their health or environmental effects ≥1% for non-gaseous substances and ≥0.2% for gaseous substances
  • substance(s) classified as PBT or vPvB, or otherwise included on the Candidate List ≥0.1%
  • substance(s) for which there is a Community Workplace Exposure Limit

In this case the supplier must also label the mixture with the statement (EUH210) "Safety data sheet available for professional user on request".

Question
Do you recommend any software for creating and managing safety data sheets?

Answer
CHCS does not recommend any particular software. A list of some of the main providers of SDS compiling software can be found on the website of the German competent authority BAuA at http://www.baua.de/en/Topics-from-A-to-Z/Hazardous-Substances/Safety-data-sheet-software.pdf?__blob=publicationFile.

CHCS News

European Council adopts revision to the EU CLP Regulation
The Council of the European Union has adopted the final text revising the EU CLP Regulation (EC No. 1272/2008), on the classification, labelling and packaging of chemical substances, which is the final step in the decision-making procedure. CHCS members can read more on our News Briefings page [Posted on 15 October 2024]

Guidance from the Government: What to do in a chemical emergency
The Government has published new guidance entitled ‘What to do in a Chemical Emergency’. The advice on the immediate actions to be taken include seeking shelter, decontamination and keeping informed. CHCS members can read more on our News Briefings page [Posted on 14 October 2024]

HSE Article 37A consultations
The HSE have opened three consultations under Article 37 A of GB CLP. CHCS members can read more on our News Briefings page [Posted on 10 October 2024]

European Commission decision to restrict undecafluorohexanoic acid (PFHxA) and PFHxA‑related substances
The European Commission has issued the regulation restricting the use of undecafluorohexanoic acid (PFHxA) and PFHxA‑related substances under European REACH: Regulation 1907/2006 on the Registration, Evaluation, Authorisation and Restriction of Chemicals. CHCS members can read more on our News Briefings page [Posted on 9 October 2024]

DGSA Survey
The Department for Transport is conducting a DGSA survey by way of a call for evidence, aimed at DGSAs and organisations dealing with the transportation of dangerous goods. CHCS members can read more on our News Briefings page [Posted on 7 October 2024]

22nd ATP to CLP published
The 22nd Adaptation to Technical Progress (ATP) to the Regulation on the classification, labelling and packaging of substances and mixtures (CLP) has been published. CHCS members can read more on our News Briefings page [Posted on 3 October 2024]

23rd ATP sent to WTO
The 23rd Adaptation to Technical Progress (ATP) to the CLP Regulation, Regulation (EC) No. 1272/2008 has been notified to the World Trade Organisation, Technical Barriers to Trade (WTO-TBT) Committee. CHCS members can read more on our News Briefings page [Posted on 2 October 2024]

Highlights from September’s RAC and SEAC meetings – including the RAC opinion on the harmonised classification and labelling of Talc
The Highlights from September’s RAC and SEAC meetings have been published on the ECHA News website. CHCS members can read more on our News Briefings page [Posted on 27 September 2024]

IATA 66th Edition of the DGR
The International Air Transport Association (IATA) have published the significant changes and amendments in the 65th edition (2025) of the Dangerous Goods Regulations (DGR). CHCS members can read more on our News Briefings page [Posted on 24 September 2024]

CHCS' September 2024 Newsletter is now available, containing several important updates on the many recent changes to the regulation framework. See CHCS September 2024 Newsletter [Posted on 20 September 2024]

IATA – dangerous goods video – 66th edition of the DGR
The International Air Transport Association (IATA) have published a video of the changes to the 2025 66th edition of the Dangerous Goods Regulations. CHCS members can read more on our News Briefings page [Posted on 18 September 2024]

Poison centres – Member States intentions document updated
The document produced by the European Chemicals Agency (ECHA) on the overview of Member States decisions in relation to implementation of Annex VIII to CLP Regulation has been updated. CHCS members can read more on our News Briefings page [Posted on 16 September 2024]

Help HSE Build their AI Knowledge Base
The HSE are looking to develop a database of uses of AI in the workplace. To develop this database, HSE are undertaking a project to gather information of real-world examples of AI use, which could impact health and safety, across the industry sectors that we regulate. CHCS members can read more on our News Briefings page [Posted on 11 September 2024]

HSE Survey on the GB CLP Regulation
The Health & Safety Executive (HSE) is looking for feedback from manufacturers, importers, downstream users and distributors (Great Britain and Northern Ireland) on ‘how the current GB CLP system is working.’ CHCS members can read more on our News Briefings page [Posted on 5 September 2024]

EU CLP Corrigendum Text
The CLP corrigendum text has been approved today in ENVI committee. CHCS members can read more on our News Briefings page [Posted on 4 September 2024]

K-REACH registration deadline approaching for existing substances in 100-1000 tonnes/annum volume threshold
Manufacturers and importers in South Korea are responsible for registering chemical substances with the Ministry of Environment when the volume exceeds one tonne per annum (t/a), according to the Act on the Registration and Evaluation of Chemicals (otherwise known as K-REACH). CHCS members can read more on our News Briefings page [Posted on 2 September 2024]

Australia updates downloadable Inventory of Industrial Chemicals
The latest update to the Australian Inventory of Industrial Chemicals is available to download as a spreadsheet in Excel format. CHCS members can read more on our News Briefings page [Posted on 29 August 2024]

Updates to the EU Chemicals Legislation Finder
The EU Chemicals Legislation Finder (EUCLEF) is a useful tool for obtaining regulatory information on substances of interest and to check regulatory obligations. CHCS members can read more on our News Briefings page [Posted on 27 August 2024]

ECHA RAC adopts Seven opinions on harmonised classification and labelling
The European Chemicals Agency Risk Assessment Committee (ECHA RAC) has adopted seven opinions on harmonised classification and labelling (CLH). CHCS members can read more on our News Briefings page [Posted on 9 August 2024]

ECHA RAC adopts two opinions on occupational exposure limits
The European Chemicals Agency Risk Assessment Committee (ECHA RAC) has adopted two opinions on occupational exposure limits under the Carcinogens, Mutagens or Reprotoxic substances Directive (2004/37/EC). CHCS members can read more on our News Briefings page [Posted on 8 August 2024]

CHCS Webinar: An overview of the United States Toxic Substances Control Act (TSCA)
CHCS have now published the slides and recording from the webinar. CHCS members can access these on the Past Events page of the website [Posted on 26 July 2024]

Update to the Consultation on UK REACH
The period to comment on the Alternative Transitional Registration model proposed under UK REACH for application in Great Britain has been extended. CHCS members can read more on our News Briefings page [Posted on 21 June 2024]

CHCS Webinar: Canada Consumer Chemical Product Labelling
CHCS have now published the slides and recording from the webinar. CHCS members can access these on the Past Events page of the website [Posted on 14 June 2024]

CHCS Webinar: United States Consumer Chemical Product Labelling
CHCS have now published the slides and recording from the webinar. CHCS members can access these on the Past Events page of the website [Posted on 12 June 2024]

OSHA has issued a final rule that updates the Hazard Communication Standard (HCS) OSHA has issued a final rule that updates the Hazard Communication Standard (HCS) to align primarily with the seventh revision of the United Nations’ Globally Harmonized System of Classification and Labelling of Chemicals (GHS). CHCS members can read more on our News Briefings page [Posted on 21 May 2024]

Endocrine Disruptors - 1st CHCS Video

We have produced our first video for members: "Endocrine Disruptors", which is available to members free-of-charge.

This introductory video explains the various components of the human endocrine system and how they interact, to help understand the mechanisms of endocrine disruptors on human systems.

The video is just over 10 minutes long.

For access to the video, please visit: Endocrine Disruptors Video.

[Posted on 1 July 2019]

CHCS News Summary

  • European Parliament votes on key legislation & European Commission announces guiding criteria for essential use (25 April 2024)
  • Amendments to the GB Cosmetics Regulation (15 April 2024)

  • (9 April 2024)The Health & Safety Executives Call for Evidence on PFAS in firefighting foams and the EU moves forward with the PFHxA restriction

  • ECHA Enforcement Forum: Checking poison centre notifications & compliance of products sold online (2 April 2024)

  • The Health and Safety Executive notifies proposed MCL for 48 hazardous chemicals to the World Trade Organisation (27 March 2024)

  • The European Chemicals Agency publishes latest Assessment of Regulatory Needs Reports (26 March 2024)

  • GB MCL List Update (15 March 2024)

  • Latest United States TSCA Inventory is now available (23 February 2024)

  • The United States Environmental Protection Agency notifies a significant new use rule for 329 PFAS to the WTO (21 February 2024)

  • The HSE UK REACH Report and Work Programme (19 February 2024)

  • The European Chemicals Agency publishes new chemicals database (1 February 2024)

  • EU Candidate List Substances of High Concern updated (31 January 2024)

  • Turkey extends KKDIK registration deadlines (29 January 2024)

  • ECHA issues updated Guidance for the identification and naming of substances under REACH and CLP (26 January 2024)

  • The Health and Safety Executive recommends diisohexyl phthalate for inclusion in the UK REACH Authorisation List (25 January 2024)

  • 21st ATP to CLP Published (10 January 2024)

                CHCS Members can read these News items, and older posts, on the CHCS News Briefings page.

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