Summary of SDSs
SDSs are required by law for industrial and professional users for both substances and mixtures which are classified for CLP, or have EUH statements, or hold WELs. They may also be produced voluntarily for products which do not require an SDS but require information to be communicated down the supply chain (as listed in Article 32 of REACH); or for products which have no requirement to have an SDS, but customers expect one.
The SDS should be authored by a “competent person”, although there are no details on what this means in practice. TT Environmental consider that, as a minimum, the SDS author requires a basic level of chemical knowledge, together with practical experience in handling chemicals, and access to people with COSHH, transport and other specialist knowledge.
The SDS requires information on the safe handling of the product, and information on first aid, what to do in an emergency etc. This information may be obtained from people in your business who handle to product on a daily basis, e.g. production operators, lab staff; from your Health and Safety officer; etc. You may also want to contact your customers to find out how they use the product on a practical level, as this will help you understand what information will be useful, and how it could best be expressed.
The current SDS format is in 16 sections, as it was under CHIP, but now includes a further 49 sub-sections. (The order of information has changed slightly compared to CHIP). Information is required under each section and sub-section, you can no longer omit these headers from the SDS, or put “not applicable”, although “no data available” is acceptable.
The SDS uses the CLP classification, and many substances have classification(s) published on the ECHA database which can be used for either substance classification, or for component substances in a mixture. Where a substance has gone through the REACH registration process, there is also a lot of published data which can be used in the SDS, and registrants are legally obliged to ensure that the data on their SDS matches that of the registration dossier. Companies which have not joined a REACH registration can also see this data online, although it is a grey area as to whether they can legally use it, although ECHA are encouraging companies to use the CLP classifications within REACH dossiers.