SDS competent person

SDSs must be compiled by a “competent person”.  This is not defined in REACH, but there is guidance in ECHA SDS document section 2.5.

The authors of the ECHA guidance recognise that an SDS may require input from different specialists, e.g. a regulatory affairs person to classify a product; an occupational Health and Safety person, or COSHH specialist, to provide advice on worker protection and PPE; a process safety specialist to provide advice on fire and explosion prevention etc.  It is also recognised that a company may outsource their SDS authoring to third party specialists.

The ECHA guidance also suggests a list of topics where training could be provided for SDS authors, but state that this is “not exhaustive”:

1. Chemical nomenclature
2. European Regulations and Directives relevant to chemicals and their implementations into MS national legislation, applicable national legislation (in their valid current versions), to the extent that these are relevant in the compilation of SDSs
3. Relevant national or international guidelines of the respective sector association
4. Physical and chemical properties, as found in section 9 of the SDS
5. Toxicology/eco-toxicology, as found in sections 11 and 12 of the SDS
6. First aid measures
7. Accident prevention
8. Measures for safe handling and storage
9. Transport provisions
10. National provisions

The guidance also notes “If SDSs are to be compiled for explosives, biocides, plant protection products15, or surfactants additional knowledge on specific products legislation applicable to them is needed”.

It is more helpful to consider the people who may be involved in compiling an SDS.  It is TT Environmental’s opinion that the overall author of an SDS should have:

• a good idea of how the product is used and handled on-site, and at your customers’ sites.
• sufficient knowledge of chemistry to be able to check the hazard classification, understand the intrinsic hazards of the product, and be able to check that the physical and chemical properties are included in Section 9 of the SDS
• depending on the level and types of hazard of the product
  • knowledge of, or access to, a COSHH specialist for advice on first aid, storage, workplace exposure limits etc
  • knowledge of, or access to, a toxicologist or eco-toxicologist
  • knowledge of, or access to, a process safety specialist for advice on fire/ explosion prevention and dealing with major accidents
  • knowledge of, or access to, a DGSA (Dangerous Goods Safety Advisor) for advice on Transport classification
  • access to the Fire Service for specific fire fighting advice
  • access to a medical specialist for specific first aid and medical advice

For hazardous materials, someone who is educated in chemistry and has practical hands-on knowledge of chemical risks is a good choice to compile the SDS, e.g. with an A-level, HNC, HND, degree or similar would be a good choice.  If that person has some COSHH experience, or access to a chemical Health & Safety manager (or person with that role in the business), so much the better.

A specialist, such as a toxicologist, may be less useful for compiling an SDS, as they may be very good in their own sphere, but lack experience in the other disciplines.  Similarly, someone who understands e.g. logistics and warehousing, but who does not have any basic chemical knowledge, may be at a disadvantage in compiling the SDS, unless it is for very low hazard materials.

If your company does not have anyone educated in chemistry, it is suggested that you consider using a specialist to either compile your SDSs for you, or to check that your SDSs are of an acceptable standard.