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Definition of Safety Data Sheet
Understanding the Role and Importance of Safety Data Sheets (SDS) in Chemical Control
Based on the text in chapter 1.5 of the UN GHS revision 5 13:
The Role of Safety Data Sheets (SDS) in Chemical Control
The Safety Data Sheet (SDS) should offer detailed info on substances or mixtures, vital for workplace chemical regulations.
Crucial Information Source for Workplace Safety
Both employers and workers use it as a source of information about hazards, including environmental hazards, and to obtain advice on safety precautions.
Limitations of SDS in Workplace Specificity
The SDS is product related and usually [in the absence of relevant attached exposure scenario(s)] is not able to provide specific information that is relevant for any given workplace where the product may finally be used, although where products have specialized end uses the SDS information may be more worker-specific.
Empowering Employers and Protecting the Environment
The information therefore enables the employer (a) to develop an active programme of worker protection measures, including training, which is specific to the individual workplace; and (b) to consider any measures which may be necessary to protect the environment. In addition, the SDS provides an important source of information for other target audiences in the GHS.
Diverse Applications of SDS Information
Various parties benefit from specific data: those transporting hazardous items, emergency responders (even poison centers), pesticide professionals, and consumers. However, these audiences receive additional information from a variety of other sources such as the UN Recommendations on the Transport of Dangerous Goods, Model Regulations and package inserts for consumers and will continue to do so. Consequently, the implementation of a unified labeling system won’t alter the SDS’s main purpose: assisting workplace users.
SDS Format and Compliance with REACH Regulation
Annex II of REACH defines how EU and REACH-adopting countries present the SDS format and content.
Clarity and Accessibility
The SDS must convey info clearly and concisely, maintaining coherence through well-structured sentences.
According to REACH Regulation Article 31(5), “The safety data sheet shall be supplied in an official language of the Member State(s) where the substance or mixture is placed on the market, unless the Member State(s) concerned provide otherwise”. It should be noted that it is for the recipient Member State (MS) to provide otherwise – i.e. for example, the existence of an exemption in the MS of manufacture does not give an exemption in a different MS where the substance or mixture is placed on the market. Even if the MS provides otherwise, it may be desirable to always provide (potentially in addition) the SDS in the language of the country.
Understanding SDS Format and Content in Compliance with REACH and CLP Regulations
Article 31 and Annex II of the REACH Regulation define the format and content of SDS. The latest change is from 1.6.2015 by Regulation No. 830/2015/EC, and safety data sheets issued before 1.6.2015 must be in compliance till 31.5.2017 as a latest.
Compliance with CLP Regulation for Classification in Safety Data Sheets
Classification in the safety data sheets is in compliance with CLP Regulation No. 1272/2008/ES from 1.6.2015. For the cases where a mixture was classified, labeled, and entered the market before that date, then exemption to re-classify is valid till 1st of June 2017.
SDS Revision Triggered by CLP Regulation Update
Another reason for the SDS revision is CLP Regulation up-date (ATE) No. 918/2016/EC from 19.5.2016, where, for instance, some hazard phrases are changed (H). This regulation has to be followed from 1.2.2018 as a latest.