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


New CHCS Webinar: "An Introduction To In Silico Toxicology – (Q)SAR And Read-Across"
To be presented by Dr. Elena Fioravanzo, of ToxNavigation Ltd. 15 September 2020, 13:30 BST. Register Now (free of charge for members of CHCS).  [Posted on 24 July 2020]

CHCS Statement On Coronavirus / COVID-19
In response to the uncertainty around the COVID-19 pandemic, we have prepared a statement on how we are responding to the challenges this raises. You can read the current statement at: Coronavirus / COVID-19. We will update this as and when necessary[Updated on 19 May 2020]

Option To Anonymise The Unique Formula Identifier (UFI)
The Unique Formula Identifier (UFI) generator has been updated to allow companies to chose not to use their company VAT number to create their UFIs.
CHCS members can read more on our News Briefings page[Posted on 22 June 2020]

New ECHA CLP Guidance Documents Published 1) Guidance on labelling and packaging
2) Guidance on harmonised information relating to emergency health response.
CHCS members can read more on our News Briefings page[Posted on 26 May 2020]

Draft Regulation Amending Article 25 Of CLP
The Draft Commission Delegated Regulation amending Article 25 of Regulation (EC) 1272/2008 of the European Parliament and of the Council on classification, labelling and packaging of substances and mixtures as regards bespoke paints is now available. CHCS members can read more on our News Briefings page. [Posted on 19 May 2020]

Draft Second Amendment to Annex VIII of CLP
The European Commission have published the Draft Commission Delegated Regulation amending Regulation (EC) No 1272/2008 of the European Parliament and of the Council on classification, labelling and packaging of substances and mixtures. This is the second amendment to Annex VIII of CLP, otherwise known as poison centres. CHCS members can read more on our News Briefings page. [Posted on 23 April 2020]

Reminder: 13th ATP to CLP applicable from 1st May 2020
The 13th Adaptation to Technical Progress (ATP) to the Regulation on the classification, labelling and packaging of substances and mixtures (CLP) is applicable from 1 May 2020 and contains updated classification and labeling for a number of substances. CHCS members can read more on our News Briefings page. [Posted on 23 April 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
  • 23 March 2020
    Multilateral Agreements For ADR & RID

  • 17 March 2020
    The Carriage of Dangerous Goods and Use of Transportable Pressure Equipment (Amendment) (EU Exit) Regulations 2020

  • 3 March 2020
    UK Chemical Industry: Regulatory Divergence

  • 2 March 2020
    Corrigendum To the 14th ATP Published

  • 10 February 2020
    Third Corrigendum To ADR 2019 Published

  • 13 January 2020
    Poison Centres - Annex VIII amendment published

  • 21 November 2019
    CHCS 2019 AGM & Annual Lectures: Presentations Now Available

  • 21 November 2019
    Commission Directive (EU) 2019/1831 Establishes  A 5th List Of Indicative Occupational Exposure Limit Values (IOELVs)

  • 12 November 2019
    ECHA publishes draft CoRAP for 2020-2022

  • 22 October 2019
    GHS Revision 8

  • 21 October 2019
    Model Regulations, 21st Revised Edition

  • 20 October 2020
    IATA Publishes Significant Changes To The 61st Edition Of The Dangerous Goods Regulations

  • 20 October 2019
    CHCS October 2019 Newsletter Now Published

  • 1 October 2019
    Draft amendment to REACH Annex II

  • 30 September 2019
    Poison Centre First Deadline To Be Postponed

  • 23 September 2019
    Updated advice for UK-based companies intending to export chemicals listed in the Prior Informed Consent (PIC) Regulation to EU countries in the period immediately following the UK’s withdrawal from the EU

  • 28 August 2019
    14th ATP To CLP: Outcomes For TiO2, Cobalt & DPTA

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

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    For a full list of our CHCS Training Courses, please visit our Training page. 

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