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Responsibilities of Safety Data Sheet Preparation
The manufacturer, importer, or only representative holds the primary responsibility for creating the safety data sheet. Moreover, they should foresee, to the extent possible, the potential uses of the substance or mixture.
Actors further down the supply chain should also provide a safety data sheet, drawing on, checking the adequacy of, and adding to the information provided by their suppliers to cater for the specific needs of their customers.
Compliance with REACH Regulations for Safety Data Sheets
Where there is a chain of supply, the requirements of REACH in relation to the provision of safety data sheets apply at each stage of the supply chain.
In all cases, suppliers of a substance or a mixture which requires a safety data sheet have the responsibility for its contents, even though they may not have prepared the safety data sheet themselves. In such cases, the information provided by their suppliers is clearly a useful and relevant source of information for them to use when compiling their own safety data sheets. However, they will remain responsible for the accuracy of the information on the safety data sheets they provide (this also applies to SDSs distributed in languages other than the original language of compilation).
Above all, the text of the Revision of Annex II specifies in point 0.2.3 that: “[…] The safety data sheet shall be prepared by a competent person after that shall take into account the specific needs and knowledge of the user audience, as far as they are known. Suppliers of substances and mixtures shall ensure that such competent persons have received appropriate training, including refresher training.”
Article 31 and Annex II of the REACH Regulation establish the format and content for safety data sheets (SDS). Regulation No. 830/2015/EC brought change on 1.6.2015. Earlier safety data sheets need compliance by 31.5.2017.
Classification in the safety data sheets is in compliance with CLP Regulation No. 1272/2008/ES from 1.6.2015. Then exemption to re-clasify is valid till 1st of June 2017.
Other reason for the SDS revision is CLP Regulation up-date (ATE) No. 918/2016/EC from 19.5.2016, were e.g. some hazard phrases are changed (H).