CLP classifications on supplier SDSs
Supplier Safety Data Sheets (SDSs), or SDSs from reputable third-parties such as large chemical suppliers, can contain useful information for classifying substances, particularly information on component substances needed for a mixture classification.
All CLP and GHS classification information should be placed on a GHS-compliant SDS, which means the classification sits in Section 2.1 of the SDS.
For dual-classified CHIP-CLP SDSs, which were legal for mixtures during the period 2010 to 2015, the CLP classification information is likely to be in Section 15 or Section 16, as it is subsidiary to the CHIP classification.
However, if you have an old CHIP-only SDS, the CHIP classification information will be held in Section 15, regulatory information.
Some tips on finding good-quality SDSs
As well as searching for SDSs using the internet, when you can sometimes end up with non-EU SDSs, or SDSs purportedly written to REACH/CLP standards but obviously compiled by people outside the EU with limited knowledge, you can also look at obtaining SDSs direct from distributor or manufacturer websites.
SDSs can often be obtained from reputable company websites, particularly from those based in the EU. This can sometimes be open-access, such as the Sigma Aldrich (now Merck) website at https://www.sigmaaldrich.com/united-kingdom.html . Other chemical suppliers may require you to sign up for a free log-in, such as the Tennants Distribution website at http://www.tennantsdistribution.com/ . However, some companies require you to be a paying customer before they allow you to access their SDSs.
There are also companies who hold libraries of SDSs, and may send you a copy in return for your email address, and these can be useful for products which have been altered, or which are no longer sold, but are still working their way through the supply chain (this can apply particularly to products which do not have a shelf-life or deteriorate in storage, and are still good quality e.g. 10 years after manufacture).
Whenever you obtain a third-party SDS, you should always treat it with caution:
- has it been compiled by a reputable company?
- does it have data in it, or is it quite “empty”
- does the GHS/CLP classification look reasonable
- if it is outside the EU, or doesn’t have a GHS classification, can the data still be used to generate a CLP classification
- overall, do you trust it? would you be happy to stand up in court and explain why you based your own classification on one in another company’s SDS, or on their data