Safety Data Sheet (MSDS) preparation

Preparing Safety Data Sheets in compliance with REACH regulation

Safety Data Sheet (SDS) service includes:

reach szolgáltatásChecking the validity and usability of the current safety data sheet
reach szolgáltatásPreparing new or updated safety data sheet
reach szolgáltatásIf possible, preparing GHS classification
reach szolgáltatásTranslating the safety data sheet into other languages

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Safety Data Sheets as required by REACH

It is a well-known requirement that suppliers of hazardous substances and preparations provide a Safety Data Sheet to the recipients at the first supply. REACH details the requirements of a safety data sheet in Article 31 and 453/2010/EU regulation.

Safety Data Sheets must be prepared for persistent, bioaccumulative and toxic, the so called PBT-substances, for very persistent, very bio-accumulative, the so called vPvB-substances and for a dangerous substances and dangerous preparations.

If there is an orange colored hazard symbol at sections 2 of the safety data sheet, then the substance or preparation is qualified as dangerous /hazardous. Therefore, while from the point of view of pre-registration or registration it didn’t matter if the substance was categorized dangerous, for the safety data sheet this must be indicated. In my experience suppliers provide safety data sheets even for chemical substances and preparations categorized as non-dangerous, thus making the work of environmental health and safety colleagues easier. REACH accepts the indication of non-dangerous chemical substance using different ways of communication, not only through the use of safety data sheet.

It is required to prepare a safety data sheet according to the 453/2010/EU regulation for hazardous substances and mixtures from 1st of December 2012.

REACH requires that in section 1 of the safety datasheet the registration number must be indicated, but as we know most substances will only receive the registration number by 2010, 2013 or 2018. Until then producers and importers can only provide the pre-registration number.

From a local EU distributor you should only accept a safety data sheet written in local EU language. The REACH regulation allows that European Union suppliers provide safety data sheet in an official language of the EU Member States (Article 31.5). If possible, downstream users should not modify the safety data sheet provided by the supplier.

According to REACH, the use of a substance or preparation following the completion of the registration must be indicated in section 1.2 of the safety data sheet. Communication about this has already begun between producers and buyers. If the buyer receives such a questionnaire from the producer or importer, they must fill that in to the best of their knowledge and return it to the producer or importer. This is important because if the usage of the buyer is not indicated in the registration dossier, they may have problems with the usage of the substance later. REACH requires that if a buyer indicates their use of the substance 12 months prior to registration deadline of the producer or importer, the producer or importer is obligated to check this use during the registration. If the use means an acceptable level of hazard, they must include this among the identified uses. If, following the completion of the registration, the buyer cannot find its own usage on the safety data sheet refreshed by the producer, they must indicate the discrepancy to the producer and ask them to prepare the evaluation also for the buyer’s conditions. If the producer indicates that they do not recommend usage of the hazardous substance or preparation for the conditions given by the buyer, this must be indicated by both parties to the European Chemical Agency, and only after this can the producer transport the chemical substance to the buyers premises. In this case the buyer needs to prepare the chemical safety assessment if his use exceeds 1 ton /year.

Communication has begun within the supply chain about gathering a list of the uses. The most frequently used tool is that prepared by Cefic, called “use descriptor system”

If the substance requires authorization or there is a restriction of its uses, information regarding this must be indicated on the safety data sheet. If the registration requires, the ‘exposition scenario’ must also be attached to the safety data sheets.

Safety data sheets must be retained for 10 years, or in the case of carcinogen substances for 40 years (this last one is not REACH requirement).

REACH requires that producers or importers or mixers of hazardous preparations must prepare a categorization of the hazard. Currently for hazardous substances the categorization should be made based on 67/548/EEC, “DSD” and according to the new CLP (GHS) (1272/2008/EK) regulation in the 2nd and 3rd point of the SDS.

For hazardous mixtures the categorization should be made based on 1999/45/EC, “DPD” legislation, or according to the new CLP (GHS) (1272/2008/EK) regulation in the 2nd and 3rd point of the SDS.

For further information about the CLP (GHS) regulation, please refer to the website.

Fundamental changes regarding the content of the Safety Data Sheets can only be expected with the introduction of the new global hazard symbols, and also after the registration dossiers have been completed. Based on these producers and importers will be able to attach the exposition schemes, as well as the usage and application information to the renewed Safety Data Sheets.