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Safety Data Sheet - FAQ
Safety Data Sheets - Frequently Asked Questions
Q What does the legislation require concerning the SDS Compiler Competence?

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 Requirements then says "Suppliers of substances and mixtures shall ensure that such competent persons have received appropriate training, including refresher training."

This is basically the same as applied under the pre REACH provisions (E.g. CHIP3 and the L130 Approved Code of Practice: The compilation of safety data sheets).

There is no further official EU requirement or guidance as to what constitutes appropriate training/refresher training. There is no 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 chemist then there is no need to attend Module 2 - Chemistry for non-chemists. 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 Modules can be found on the website.

Unfortunately, with current demand, CHCS normally offers each Module only once a year, which might mean that a person 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.

Q 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?
A REACH Regulation Article 31(1) requires that you shall 'provide' a safety data sheet to the recipient. Where an update has been prepared as required by Article 31(9) then it must be provided to those who have received the chemical within the last 12 months. Posting this information on your website is 'making available' the information and not 'providing' it and therefore you would not be complying with REACH. The question of electronic/fax/mail provision of SDSs by electronic means (fax or e-mail) is one that you have to agree with your customers. All formats are acceptable only if your customers are in a position to receive and handle that information.
Q Do I have to supply overseas customers with SDSs in their language?
A EU Member States and several non EU countries make the placing of dangerous substances or preparations on the market in their territory subject to the use of their official language or languages for the compilation of safety data sheets. 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 provide otherwise.
Q Whose name and address should appear in section 1 of the SDS?
A The name and address should be of the "person placing the
substance or preparation on the market” who can be the manufacturer, importer or distributor based in the EEA. If the manufacturer is outside the EEA (note: even if in Switzerland) then an EEA name & address is mandatory. The UK SDS ACoP recommended that if the supplier is not located in the UK, then, if possible, the details of the person based in the UK responsible for the goods should also be on the SDS.
Q Why is Xn the abbreviation for the harmful symbol?
A The "n" in Xn stands for Nocif, the French for Harmful; the original 1967 Directive used the first letter of the French-language Indications of Danger, except for oxidiser, which would have been another "C" (comburant).
Q If a preparation has been classified as non-dangerous does that mean that I don’t need to produce a Safety Data Sheet?
A Its not necessarily true that non-dangerous chemicals are not regulated by the REACH Regulation some preparations which are not classified as dangerous but which contain >=1% by weight (non-gaseous preparations) or >=0.2% by weight (gaseous preparations) of either a dangerous substance classified in respect of its health or environmental effects or a substance for which there is a Community workplace exposure limit  must label with "Safety data sheet available for professional user on request" and must prepare a safety data sheet containing 'proportionate information'.
Q Do you recommend any software for creating and managing safety data sheets?
A 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


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