Section 1 of the SDS
In the SDS, SECTION 1: Identification of the substance/mixture and of the company/undertaking comprises:
1.1 Product identifier
1.2 Relevant identified uses of the substance or mixture and uses advised against
1.3 Details of the supplier of the safety data sheet
1.4 Emergency telephone number
Section 1 of an SDS should be on the first page of the SDS, and this means that a cover sheet should not be used. It is understood that this is to ensure that the most important information is available to the reader on the first page, and they have access to the identity of the product, and contact information needed in an emergency.
1.1. Product identifier
The product identifiers should be the same as used on the CLP label, that is:
- either substance chemical name and identification number(s), e.g. CAS number, and/or EC number
- or mixture trade name
This section should also contain:
- the REACH registration number, if the substance has been registered for REACH. The number can either be published in full, in the format XX-XXXXXXXXXX-XX-XXXX; or the last four digits (which identify the registrant) may be omitted. Omitting the last four digist of a REACH registration number should be done where you are reselling a substance from more than one REACH-registered supplier, or where you do not wish to indicate that you are using a specific supplier.
Notes about Section 1.1:
- the Authorisation number does not go here, it goes in Section 2.2, Label elements, because it is not part of the formal identification of the product.
- the UFI, Unique Formulation Identifier, has just been brought in for some types of mixture, and this will be placed on the CLP label. However, at the time of writing, May 2017, there is currently no guidance about whether it should be listed in Section 1.1 or Section 2.2 of the SDS. If you are an “early adopter” of UFIs, it may be prudent to place the UFI in both sections of the SDS until guidance has been issued.
- there is no requirement to put the “contains” information after a mixture trade name, because these component substances (and others) are identified separately in Section 3.2. This also applies to substances containing significant impurities. Some SDS authors include it as a “nice to have”, however others consider this is too much detail, and the trade name is sufficient to identify the mixture at this point of the SDS.
1.2. Relevant identified uses of the substance or mixture and uses advised against
If not REACH registered: list uses relevant to the recipient(s) of the product. This is a brief description, e.g. “flame retardant”, “antioxidant”, “industrial colourant” “colouring agent” etc.
List any uses which are advised against, and state why (need not be exhaustive, eg “do not use as food colourant”, or “not for personal care or food use”). You should include any uses which are banned under an authorisation.
If REACH registered: supply the same information, but it must be consistent with the identified uses in the Chemical Safety Report and relevant exposure scenarios included in Annex I of this SDS. n.b. the full list of REACH uses is required for REACH-registered substances in section 7.3, this section is intended to be a summary.
Important note about uses: you may wish to include a statement such as “industrial use only”, if the product should not be used for consumer uses. The PIP breast implant scandal of 2010, caused by a French company using industrial silicone gel for a cosmetic use, could have affected the supplier of the silicone gel (Rhodia, now part of Solvay), but it is understood that Rhodia’s SDSs and other technical literature explicitly stated “industrial use only”, and they were not held liable for what was a clear mis-use of the product, or violation of instructions, by the company making the dodgy implants.
1.3. Details of the supplier of the safety data sheet
In theory, you only need four pieces of information in this section:
Supplier name: Company name
Supplier address: Company address
Supplier telephone: Company telephone number
Email: Email address for a competent person responsible for the SDS. (Note – it may be better to have a generic email address which can be forwarded to the relevant person or team, e.g. email@example.com, rather than an individual’s email, in case they leave the company at a later date).
If your substance is REACH registered by you (rather than a supplier) this contact information must be consistent with the information on the identity provided in the registration.
Where you are reselling, or acting as an agent, and want to provide the manufacturer’s information as well are your own information (which is legally required as the commercial supplier), this can also be added (in the UK at least, this point has been checked with the HSE helpdesk). For clarity, you may wish to identify the information under two headings eg: “manufacturer”, “seller” (or similar). This can be useful if you are a reseller who wants people to contact the manufacturer directly in case of emergency.
Note that there is NO requirement to identify an Only Representative on the SDS, as they are responsible for REACH matters, on behalf of the ex-EU manufacturer. (Unless they are also acting as the Importer and physically selling the product).
1.4. Emergency telephone number
The emergency telephone number is different from the suppliers telephone number provided in Section 1.3 above, as it is for the provision of advice on the product in the event of an emergency, such as a spillage, fire, or accidental exposure of someone to the product.
In some countries, but not the UK, the emergency telephone number has to be a relevant Poison Centre number, and you have to register your product with the Poison Centre before supplying it. For more details, see https://ttenvironmenta.wpengine.com/knowledgebase_category/poison-centre-notification/ .
In countries like the UK where a centralised number is not specified, this number can either belong to you, or to a private external provider of emergency support whom you have a commercial contract with. (In the UK, this is likely to be the NCEC, http://the-ncec.com/, their services are chargeable).
Regardless of who is providing the support on the end of the emergency number phone line, it must:
- be answered in the language(s) of the user’s EU member state
- be listed on the SDS under this section, together with any hours of opening, if this is not 24 x 7 x 365
- if the advice is for medical professionals only, this must be stated on the SDS
- the number can be anywhere in the world, but the SDS should have the appropriate international dialling code
- the number should be for a landline, although this can be transferred through to a mobile (e.g. out of normal working hours)
Note that if you are providing the emergency service yourself, “the necessary competence should be available”, that is you should have someone who is suitably qualified and experienced to deal with these queries, and the phone number should be answered by that person.
Some SDSs list Emergency Numbers which are Premium Rate, and attract charges over and above the normal telephone charges for anyone dialling them. Although this does not appear to be illegal, it certainly cannot be described as good practice, particularly when one considers that SDSs themselves are to be provided free of charge. It is recommended that a normal geographic telephone number is used (where you have a choice).
In the UK, the National Poisons Information Service telephone number should not be placed on the SDS, as it is for medical professionals only. However, the NPIS advise the following on their website:
The UK Government has stated that, “The emergency telephone number in section 1.4 of the safety data sheet should give access to advice for product users in case of problematic exposure. The advice should preferably be given by an appropriate person from the supplier, or from an organisation contracted by the supplier for this purpose. However, suppliers may wish to also include in section 1.4 the recommendation that the enquirer should call NHS 111 or a doctor.
So you can add this extra information on your SDS under Section 1.4, as well as supplying your own emergency telephone number, if you think it is appropriate.