Section 2 of the SDS

In the SDS, SECTION 2: Hazards identification comprises:

2.1. Classification of the substance or mixture
2.2. Label elements
2.3. Other hazards

2.1 Classification of the substance or mixture

The CLP classification of both substances and mixtures is required here.  This should include the hazard class (the type of hazard, e.g. flammable liquid and vapour, or acute toxicity (oral)), the hazard category (degree of hazard, e.g. category 1, or category B etc), and the H code (e.g. H300).

Notes about Section 2.1

• If you use any abbreviations, e.g. H codes in this section, they must be listed in full in Section 16 (e) together with their full text
• CHIP classifications for mixtures should not be placed here any more, but can be voluntarily placed under “other information” in Section 16, although after this date it is best practice to omit CHIP information entirely.

2.2 Label elements

CLP Hazard Pictograms: the pictogram(s) should be shown here, either with a red border or grey border. There is no requirement to give the name of the pictogram.  (If no pictogram applies it is good practice to put in words “no pictogram applies” or similar).

Signal Word:  Danger or Warning (or “no signal word”,  or simply leave blank)

Hazard Statements:  list the full text of each H Statement as shown on the label, it is optional to use the H code.  

Precautionary Statements: list the full text of each P statement as shown on the label (maximum 6 or 7). It is  optional to use the P code.

EUH Statements: list the full text of each EUH statement here, the EUH number is optional. 

If Authorised: Authorisation number (this also applies to any component substances which hold authorisation number(s).

If Restricted (under Annex XVII of REACH): Any required label elements such as text like “Restricted to professional users”

If there are any other label elements required under national legislation: in the UK, this would include extra labelling information required for aerosols; or for laundry liquitabs; or other special cases.

If a mixture holds a Unique Formulation Identifier, UFI: The UFI may be required to go here, or in Section 1.1 of the SDS. Guidance has not been issued at the time of writing, May 2017, so if you are an “early adopter” of UFIs, you may wish to place the UFI in both sections of the SDS as a precaution.

Notes about section 2.2:

• Although this section is about label elements, the product identifiers are not repeated here as they have already been given in Section 1.1 of the SDS
• Section 2.2 is the main place on the SDS for EUH statements, as they are not part of the formal CLP-GHS classification (although they can also be included in section 2.3 below)
• If the product is not classified under CLP,  you may want to put in text “not classified”, or “not classified under CLP” or similar wording, to make it easier for the reader to understand, rather than having to read everything several times.  In the case of a material which is not classified but is labelled for EUH208, you may want to make this clear in the text, e.g. “not classified for CLP-GHS but EUH208 applies”.
• In principle, the information here should match that on the product label, so if you have a product which is classified H400 / H410 but you are only showing H410 on the label, then only H410 should be listed here.
• If you are using H codes, P codes and EUH codes instead of the full text, you will need to put the abbreviations with the full text in Section 16(e).
• You can put “not applicable”, or “none” if e.g. there are no EUH statements, or simply omit the title text
• You may wish to list all the “unused” P statements generated by the hazard statements here (this option exists in some editions of Safeware Quasar), or in Section 16.  It is good practice to include all the P Statements on the SDS for anyone classifying a mixture containing your product, but less confusing if they are listed in Section 16.

2.3 Other hazards

PBT: Product is classified as PBT/ is not classified as PBT/ has not been tested for PBT. (Use the applicable statement).

vPvB: Product is classified as vPvB/is not classified as vPvB/ has not been tested for vPvB.(Use the applicable statement).

SVHC: Product is an SVHC/ is not an SVHC/ contains one (or more) SVHCs (name the substances)/ does not contain SVHCs at a reportable level (Use the applicable statement).

WELs: Product has a Workplace Exposure Limit/ does not have a Workplace Exposure Limit/ contains one (or more) substances with a Workplace Exposure Limit (name the substances)/ does not contain any substances with a Workplace Exposure Limit (Use the applicable statement).

For mixtures where the substance with a WEL is present in solution and therefore can’t be inhaled, but which has a WEL for inhalation, you may want to add a statement to the effect of: “Contains xxx in solution, which has a Workplace Exposure Limit.  If the mixture dries out, there may be inhalation risks from this substance”.  

Sensitisers: Product contains sensitisers which may produce an allergic reaction (name all sensitisers here, either down to 10% of EUH208 threshold, that is 1% of CLP threshold, or all sensitisers regardless of concentration.  This may be stating the information twice, but is better than sensitisers not being identified at all).

Dust explosion: If the product is a powder which can cause a dust explosion, use the statement “May form explosible dust-air mixture if dispersed”.

Other hazards: list other non-CLP hazards here.

This is the section where you can include all of the non-CLP hazards which would otherwise not go on the SDS, such as asphyxiation hazard, dust explosion, freezing, cross-sensitisation, if new products are released to arir during curing or hardening.  You can also include environmental effects not currently covered by CLP-GHS such as non-aqueous phase liquids (whether light, LNAPL, or dense, DNAPLs), adverse effects on terrestrial plants or animals or birds etc, and whether the product has a high Biological Oxygen Demand which could lead to a de-oxygenation incident if released to water.  See https://ttenvironmenta.wpengine.com/clp-knowledgebase/hazards-not-included-in-clp/ .

Note that these sub-sub-headings are for convenience and are not mandatory, so they can be omitted from your SDS.