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


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[Posted on 6 April 2021]

CHCS' March 2021 Newsletter is now available, containing important updates on the many recent changes to regulations. See CHCS March 2021 Newsletter. [Posted on 31 March 2021]

Updates to ECHA's Brexit Pages & Q&As
ECHA have updated their Brexit pages and Q&A as well as the guidance on Labelling & Packaging and Annex VIII to CLP. CHCS members can read more on our News Briefings page[Posted on 17 March 2021]

New CHCS Webinar: “Brexit - Do You Know What You Don't Yet Know?”
Thursday 1st April 2021, 14:00 BST. Free-of-charge for members of CHCS, BADGP and SCHC. Visit the Brexit webinar web-page for more details and to register. 
[Posted on 7 March 2021]

Update From HSE On UK REACH
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The GB Mandatory Classification and Labelling (MCL) List includes decisions made in the 14th and 15th ATPs to the EU-CLP Regulation, which are not yet required to be complied with.
CHCS members can read more on our News Briefings page[Posted on 1 February 2021]

Update to Canada GHS (Aligned with 7th Edition)
Regulations Amending the Hazardous Products Regulations (GHS, Seventh Revised Edition) and the Order Amending Schedule 2 to the Hazardous Products Act were published in the Canada Gazette, Part I on December 19, 2020.
CHCS members can read more on our News Briefings page[Posted on 26 January 2021]

UK Exit Of EU: Resources To Help As Transition Period Ends
CHCS members can read more on our News Briefings page[Posted on 11 December 2020]

End Of UK Transition Period – HSE Podcasts Series

HSE is hosting a series of podcasts over the coming months to provide more information on the changes to how chemicals will be regulated from 1 January 2021. CHCS members can read more on our News Briefings page[Posted on 9 December 2020]

Second Amendment Of Annex VIII of CLP (Poison Centres) Is Published

The second amendment to Annex VIII to CLP, concerning poison centres was published in the Official Journal on 13 November 2020 and entered into force on 14 November 2020. CHCS members can read more on our News Briefings page[Posted on 23 November 2020]

New "Brexit" Web Pages 
As the end of the transition period is nearly upon us (31 December 2020), and we are starting to learn more about the changes to our own regulations and our future relationships with the EU, we are pleased to present you with several new web pages on specific Brexit-related topics. Please visit our website Brexit page. [Posted on 13 November 2020]

Poison Centre Portal Updated 
The poison centre portal has recently been updated to support amended Annex VIII solutions. In particular, derogations for fuels, construction products (standard formulas) and the cross-sector concept of interchangeable components. CHCS members can read more on our News Briefings page[Posted on 30 October 2020]

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.

To register for access to the video, please visit our video registration page: Endocrine Disruptors Video Registration.

[Posted on 1 July 2019]

News Briefings Summary
  • 24 August
    Member States Slowly Starting To Use The New Portal

  • 22 June 2020
    Option To Anonymise The Unique Formula Identifier (UFI)

  • 26 May 2020
    New ECHA CLP Guidance Documents Published

  • 19 May 2020
    Draft Regulation Amending Article 25 Of CLP

  • 23 April 2020
    Draft Second Amendment to Annex VIII of CLP

  • 23 April 2020
    Reminder: 13th ATP to CLP applicable from 1st May 2020

  • 23 March 2020
    Multilateral Agreements For ADR & RID

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

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