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' May 2022 Newsletter is now available, containing several important updates on the many recent changes to the regulation framework. See CHCS May 2022 Newsletter. 

The Department For Transport Has Issued A Call For Evidence
The Department for Transport has issued a Call for Evidence in relation to the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 and the RID / ADR 2021 amendments. CHCS members can read more on our News Briefings page. [Posted on 13 May 2022]

Webinar: Poly- And Perfluoroalkylated Substances (PFAS): The Gathering Storm For Chemical Regulatory Professionals, And The Industry
The presentation and recording from our webinar held on 21 April 2022 are now available to members linked from the Past Events page of our website.[Posted on 22 April 2022]

The European Commission Has Issued A Call For Evidence
The European Commission has issued a Call for Evidence on an initiative to streamline EU-level scientific and technical work on chemicals. CHCS members can read more on our News Briefings page. [Posted on 4 April 2022]

Webinar: The Regulation Of Endocrine Disruptors In The European Union
The presentation and recording from our webinar held on 29 March 2022 are now available to members linked from the Past Events page of our website. [Posted on 31 March 2022]

Poison Centres Portal - Lichtenstein Connects
The poison centre for Lichtenstein has announced that they are now connected to the poison centre portal. CHCS members can read more on our News Briefings page. [Posted on 22 March 2022]

ECHA Is Developing A New Chesar Platform
A Questionnaire has been issued by ECHA for interested parties to join a stakeholder group. CHCS members can read more on our News Briefings page. [Posted on 3 March 2022]

Webinar: Food Contact Materials Regulation In China
The presentation and recording from our webinar held on 23 February 2022 are now available to members linked from the Past Events page of our website. [Posted on 24 February 2022]

The European Chemicals Agency Is Looking For Stakeholder Input On IUCLID Published Data
The European Chemicals Agency, ECHA has launched a survey on their new ‘Data Availability’ solution. CHCS members can read more on our News Briefings page. [Posted on 14 February 2022]

DEFRA Surveys On The Provisions Of Article 33, UK REACH
The Department for Environment, Food and Rural Affairs (DEFRA) is inviting GB-based suppliers and retailers of articles to contribute to a survey regarding Article 33 of UK REACH. CHCS members can read more on our News Briefings page. [Posted on 11 February 2022]

Changes To The Misuse Of Drugs Act: Gamma Butyrolactone And 1.4-Butanediol
Following the recommendations of the UK Advisory Council on the Misuse of Drugs, tighter controls are being placed on gamma butyrolactone (GBL) and 1,4-butanediol (1,4-BD). CHCS members can read more on our News Briefings page. [Posted on 11 February 2022]

Multilateral Agreement M345
The United Kingdom has countersigned Multilateral Special Agreement 345 concerning the transport of UN 2672 ammonia solution in IBCs with a vapour pressure of more than 110 kPa (1.1 bar) at 50oC or 130 kPa (1.3 bar) at 55oC. This is under ADR under paragraph 1.5.1 of ADR. CHCS members can read more on our News Briefings page. [Posted on 8 February 2022]

NPIS Announces That Annex VIII Of EU/GB CLP 1272/2008 Applies In The UK From Jan 1st 2021
The National Poisons Information Service (NPIS) the poison centre for GB and NI has announced that Annex VIII of EU/GB CLP 1272/2008 applies in the UK from Jan 1st 2021. CHCS members can read more on our News Briefings page. [Posted on 4 February 2022]

Poison Centres Portal - Belgium Connects
The Belgium poison centre has announced that they are now connected to the poison centre portal. CHCS members can read more on our News Briefings page. [Posted on 24 January 2022]

Revision Of The REACH Regulation
Following the Roadmap issued last year, the European Commission has today launched a consultation on a revision of the REACH Regulation. CHCS members can read more on our News Briefings page. [Posted on 20 January 2022]

EAC Corrigendum Published
The National Chemical Emergency Centre have published a corrigendum for the Dangerous Goods Emergency Action Code list 2021. CHCS members can read more on our News Briefings page. [Posted on 17 December 2021]

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]

CHCS News Summary
  • Alternative Arrangements For UK REACH Registration Being Considered By Defra
    (6 December 2021)

  • CLP Annex VI Correction Published
    (17 November 2021)

  • Model Regulations, 22nd Revised Edition
    (1 November 2021)

  • The Deadline To Submit A Downstream User Notification (DUIN)
    (26 October 2021)

  • The Carriage Of Dangerous Goods And Use Of Transportable Pressure Equipment Regulations Amendments Now Combined
    (21 October 2021)

  • The Carriage Of Dangerous Goods And Use Of Transportable Pressure Equipment Regulations 2009 Amended
    (21 October 2021)

  • ECHA - Safer Chemicals Recordings Available
    (20 October 2021)

  • GHS Revision 9
    (20 September 2021)

  • UK Cosmetics Regulation
    (1 September 2021)

  • MLA 340 And RID 06/2021 Counter-Signed By The United Kingdom
    (20 August 2021)

  • Publication Of The Draft 18th ATP To The CLP Regulation
    (17 August 2021)

  • Dangerous Emails Disguised As Coming From NPIS
    (29 July 2021)

  • SDS Will Be The Focus For Enforcement In 2023
    (20 July 2021)

  • Government Updates Their Guidance On Poison Centres
    (29 June 2021)

  • Inception Impact Assessments (Roadmaps) For REACH & CLP - deadline 23:00 GMT
    (31 May 2021)

  • Poison Centre Practical Guide updated
    (20 May 2021)

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

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