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CHCS  Chemical Hazards Communication Society  Promoting the awareness of chemical hazards & improvements in their identification & communication

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

CHCS Webinar: EU CLP Changes - From Confusion to Compromise
CHCS have now published the slides and recording from the webinar. CHCS members can access these on the page of our website. Past Events [Posted on 28 February 2024]

Latest United States TSCA Inventory is now available
The United States (US) Environmental Protection Agency (EPA) has released the latest updated Toxic Substances Control Act (TSCA) Inventory. CHCS members can read more on our News Briefings page [Posted on 23 February 2024]

The United States Environmental Protection Agency notifies a significant new use rule for 329 PFAS to the WTO
The United States (US) Environmental Protection Agency (EPA) has issued a notice to the World Trade Organisation (WTO), Technical Barriers to Trade Committee regarding PFAS. CHCS members can read more on our News Briefings page [Posted on 21 February 2024]

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

The HSE UK REACH Report and Work Programme
The Health and Safety Executive (HSE), as the Agency for UK REACH on the registration, evaluation, authorisation and restriction of chemicals, has published a UK REACH Report covering the period 2022/23, along with the Agency Work Programme for 2023/24. CHCS members can read more on our News Briefings page [Posted on 19 February 2024]

The European Chemicals Agency publishes new chemicals database
The European Chemicals Agency (ECHA) has launched the much anticipated new chemicals database called ECHA CHEM, reporting that it is a ‘new solution for publishing information on chemicals’. CHCS members can read more on our News Briefings page [Posted on 1 February 2024]

EU Candidate List Substances of High Concern updated
The European Union (EU) Candidate List of substances of very high concern (SVHC) has been updated with five new chemicals. CHCS members can read more on our News Briefings page [Posted on 31 January 2024]

Turkey extends KKDIK registration deadlines
The anticipated legal text of the Turkish REACH Regulation (KKDIK), extending registration deadlines, was published in the Official Gazette late December of last year. CHCS members can read more on our News Briefings page [Posted on 29 January 2024]

ECHA issues updated Guidance for the identification and naming of substances under REACH and CLP
The European Chemicals Agency (ECHA) has updated Guidance for the identification and naming of substances under European Union (EU) REACH and CLP Regulations. CHCS members can read more on our News Briefings page [Posted on 26 January 2024]

The Health and Safety Executive recommends diisohexyl phthalate for inclusion in the UK REACH Authorisation List
In September 2023, the Health and Safety Executive (HSE), as the Agency for UK REACH published a draft recommendation for the inclusion of diisohexyl phthalate in the UK REACH Authorisation List (Annex 14). CHCS members can read more on our News Briefings page [Posted on 25 January 2024]

21st ATP to CLP Published
The 21st 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 10 January 2024]

DEFRA Publishes a Policy Statement on the New UK REACH Alternative Transitional Registration Model
The Department for Health and Rural Affairs (DEFRA) has published an outline of the new approach to UK REACH registration, following the commitment from Government to explore options for an Alternative Transitional Registration model (ATRm). CHCS members can read more on our News Briefings page [Posted on 16 November 2023]

GB CLP Mandatory List is Updated for the First Time
The Great Britain Mandatory Classification list (GB MCL) has been updated with new and revised GB MCLs for 98 substances. CHCS members can read more on our News Briefings page [Posted on 23 October 2023]

European Union Proposal for a Regulation on the Safety of Toys Notified to the WTO-TBT Committee
The European Union (EU) has notified a proposal for a new Regulation on the Safety of Toys to the World Trade Organisation, Technical Barriers to Trade (WTO-TBT) Committee, repealing Directive 2009/48/EC. CHCS members can read more on our News Briefings page [Posted on 5 October 2023]

EU Public Consultations – Candidate List Substances of Very High Concern
Public consultations are open on proposals for six substances identified as Candidate List substances of very high concern (SVHC) for authorisation of use, under European Union (EU) REACH. CHCS members can read more on our News Briefings page [Posted on 3 October 2023]

Germany Withdraws Proposal to Restrict Endocrine-Disrupting Bisphenols
Germany has withdrawn its proposal for the restriction of substances with endocrine-disrupting properties, specifically targeting bisphenols and their salts. CHCS members can read more on our News Briefings page [Posted on 27 September 2023]

Public Consultation on the Product Safety Regulatory Framework
The Department of Business and Trade (DBT) and the Office for Product Safety and Standards (OPSS) have issued a public consultation seeking views on the planned approach to product safety to ensure that the regulatory framework is ‘fit for the future.’ CHCS members can read more on our News Briefings page [Posted on 26 September 2023]

DEFRA Survey on UK REACH
The UK REACH service team in The Department for Environment Food and Rural Affairs (DEFRA), are looking for users of the service to complete a survey. CHCS members can read more on our News Briefings page [Posted on 20 September 2023]

DFT Publishes Post Implementation Review of CDG Regulations
The Department for Transport (DfT) have published the results of the Post Implementation Review of amendments to the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009, as amended in 2011, 2019 and 2020. CHCS members can read more on our News Briefings page [Posted on 6 September 2023]

United Kingdom Notifies Mandatory Classification and Labelling of 26 Substances to the World Trade Organisation
A proposed update to the Great Britain (GB) mandatory classification and labelling of 26 substances has been notified to the World Trade Organisation, Technical Barriers to Trade Committee (WTO-TBT) by the United Kingdom. CHCS members can read more on our News Briefings page [Posted on 29 August 2023]

Model Regulations, 23rd Revised Edition
The United Nations Recommendations on the Transport of Dangerous Goods, Model Regulations, 23rd Revised edition is now available in English and French. CHCS members can read more on our News Briefings page [Posted on 29 August 2023]

IATA Publishes Significant Changes to the 64th Edition of the Dangerous Goods Regulations
The International Air Transport Association (IATA) have published the significant changes to the 64th edition of the Dangerous Goods Regulations (DGR). CHCS members can read more on our News Briefings page [Posted on 24 August 2023]

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

  • GHS Revision 10 Published (7 August 2023)

  • EU REACH: PFAS Restriction Proposals (28 July 2023)

  • 20th ATP to CLP Published (25 July 2023)

  • 19th ATP to CLP Published (21 July 2023)

  • NEW - Module 81 on the New CLP Hazard Classes for Experienced Classifiers (18 July 2023)

  • NEW - Module 16 on CLP Classification Extended to Include the New CLP Hazard Classes (7 July 2023)

  • ECHA is Developing a New Data Availability System (2 June 2023)

  • Proposed New Regulation on Detergents and Surfactants (31 May 2023)

  • Annex VIII of CLP to be Revoked (22 May 2023)

  • DfT Consultation on Temporarily Increasing the Permitted Weight of Road Tankers Carrying Diesel (20 April 2023)

  • The Control of Explosives Precursors and Poisons Regulations 2023 (17 April 2023)

  • United Kingdom Signposts the World Trade Organisation, Technical Barriers to Trade Committee of the GB Mandatory Classification and Labelling List (13 April 2023)

  • 2nd IATA Addendum to the 64th Edition of the DGR (4 April 2023)

  • NCEC and DfT Newsletter (8 March 2023)

  • 21st ATP to CLP Notified to the WTO-TBT Committee (7 March 2023)

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

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