SDS and REACH

A safety data sheet (SDS) is a structured document with information about the risks of a dangerous substance or preparation, and recommendations for its safe use at work.

The SDS is a compulsory part of the product information if you supply chemical substances or preparations to your customers. The SDS forms a mechanism for the provision of appropriate information about the safety of classified substances and preparations, including information from the relative chemical safety reports for the immediate downstream users. If a chemical safety report is required (this is required for substances of which at least 10 tons are produced or imported a year), the information given in the SDS must correspond to the information in the chemical safety report. When a chemical safety report is drawn up, the relevant exposure scenarios must be included in an appendix to the SDS so easy reference can be made to the relative sections of the SDS.

With the SDS users must be able to take the necessary measures for the protection of health and the safety at work and for environmental protection. The information provided by the SDS must also suffice with regard to the conditions of Directive 98/24/EC on the protection of the health and safety of workers from the risks related to chemical agents at work. The SDS must in particular enable the employer to check if dangerous chemical agents are present at the workplace, and assess any risks of their use to the health and safety of the employees.

Under REACH the SDS obtains a more significant role, and is a key element in danger and risk management communication. The current obligations and responsibilities remain, and are extended with the obligation to include information from the chemical safety assessment in the SDS.

The supplier of a substance or preparation supplies the buyer of the substance or preparation with a safety data sheet drawn up in accordance with Annex II of the Regulation. This Annex contains the guidelines for the compilation of the safety data sheets.

Paragraph 6 of Article 31 of the Regulation indicates the sections the safety data sheet must contain. The current section 2 (composition and information about the constituents) and section 3 (identification of the dangers) change place. This change and addition of an email address to the contact details in section 1 should be implemented from the coming into force of REACH. Up until 31 May at 2400 hours you may therefore use the current legislation for drawing up safety data sheets. After the approval of the Regulation much discussion originated about this because the added value of the swapping of the two sections is zero. The cost of changing the sections can obviously not possibly be regarded as zero. This will indeed entail very significant costs. Cefic, the European Chemical Industry Council, and nine Member States have recently raised this with the European Commission. On 13 March 2007 one came to the conclusion that the swapping of the sections and the addition of the email address was only necessary when new information had to be added to the SDS. This new information concerns the information resulting from the drawing up of the registration file (exposure scenarios). The SDS must also be adapted under the influence of GHS. The SDS for pure substances will probably have to be adapted to the new classification methods from 1 December 2010. If you do not have to change anything in the SDS before this date you can swap sections 2 and 3 and add the email address together with the next changes according to GHS. Safety data sheets for mixtures will probably have to be adapted to GHS from 1 June 2015.

After the substances mentioned in your SDS are registered the registration numbers must also be added.

At present only a draft version of the RIP3.2 is available. This must practically indicate how the addition of exposure scenarios for substances produced or imported in quantities of at least 10 tons a year must take place.