Sunday, May 31, 2009

FAQs about REACH Safety Data Sheets

What is a Safety Data Sheet (SDS)?
A Safety Data Sheet (SDS) is a document containing detailed information as regards the protection of human health, safety and the environment. The SDS provides a mechanism for transmitting appropriate information on classified substances and preparations down the supply chain to the immediate downstream users.

What legislation covers the provision of SDS?
Until the 1st June 2007, the compilation and provision of SDS was specified at EU level under the SDS Directive 91/115/EEC the objective of which was to provide manufacturing operations with the information necessary regarding the hazard profiles and of, the risks associated with dangerous substances and preparations in the workplace. In June 2007 the first Titles of the REACH Regulation came into force in the EU. Title IV, Information in the Supply Chain which details the requirements for SDS came into force on 1st June 2007, resulting in the repeal of the SDS Directive 91/115/EEC.

What is new Under REACH?
The REACH Regulation introduces an obligation for Manufacturers/Importers and users of substances on their own, in preparations or incorporated into articles to communicate information on the substances within the supply chain. The main tool for the downward flow of information on the safe use of substances is the SDS. The REACH Regulation (Article 31 and Annex II) sets out the requirements for the compilation and criteria for when to provide a SDS to professional users. It is expected that both the quality and overall relevance of the SDS provided to end users (Downstream Users) will improve greatly under REACH.

There are a number of format changes required under the REACH Regulation to be introduced by the supplier of the substance, on its own, in a preparation or incorporated into an article. These changes are as follows;
- The order of sections 2 and 3 have been reversed in the layout of the SDS ;

- There is a new requirement for the name and the email address of the competent person responsible for the SDS to be included into section 1.3 of the SDS;

- The Regulation also introduces a new attachment to the SDS known as an Exposure Scenario
(ES). An Exposure Scenario is a special instruction detailing how to use a substance on its own, in a preparation or in an article so that it does not cause harm.

- Title IV, Information in the Supply Chain of the Regulation has entered into force on 1st June 2007, however, it is recognised by the Member States and the European Commission, that information which is required to be included in the new SDS in relation to hazard or exposure scenarios will, in most cases, not be available until after the first phase-in registration deadline is reached, i.e. by 1 December 2010. The Health and Safety Authority, as Competent Authority for the REACH Regulation, will be taking a pragmatic approach regarding the requirements for SDSs in this period. In essence, the formatting changes required as of 1st June 2007(email address, change of order in sections 2 and 3, etc) would not be essential to have in place from that date, provided that the information on the relevant health, physical and environmental hazards is correct. However, if an update is needed for an existing SDS or where a new SDS is required after 1st June 2007, the REACH requirements will take precedence.

- Classification and Labelling requirements for substances and preparations will also have to be amended in line with the new Global Harmonised System for Classification, Packaging and Labelling of Substances GHS.

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When must a SDS be provided for a substance/preparation (mixture)?
A SDS is required where a substance or preparation meets the classification as dangerous in accordance with Directives, 67/548/EEC or 1999/45/EC.

In general you only have to supply a SDS for products that are classified as Dangerous however, an exception is made for some chemical products which are not classified as dangerous but require an SDS because they contain quantities of a dangerous chemical above a certain level which is deemed hazardous to human health or the environment or a chemical which has been assigned a Community Workplace Exposure Limit.

Some hazard information will be provided on the product label but a SDS will provide you with more detailed hazard information. SDS’s are important documents in helping you make the workplace safe and protect the environment and more specifically, a SDS contains information that will help you carry out a risk assessment as required under the Chemicals Agents Regulations, 2001 (S.I. No. 619 of 2001).

What does a SDS contain?
An SDS contains 16 obligatory headings as specified in Article 31(6) of the REACH Regulation

The information included under these headings will help ensure that the product is used safely.

For example, the SDS should describe the hazards the chemical may present, provide information on how it should be handled, stored and disposed of and explain what should be done n the event of an accident, i.e. first aid, fire fighting measures and so on. Annex II of the REACH Regulation seta out the detailed requirements for the compilation of SDS.

Where do I get a SDS?
Whoever supplies the chemical product must also supply the SDS. The supplier might be the manufacturer, importer, distributor, wholesaler or retailer. A SDS must be supplied, free of charge on paper or electronically at or before the first delivery. You should not receive a SDS later than the product itself. However, it maybe sent separately e.g. via email, fax or post. If the Supplier updates the SDS then a copy must be sent to all former recipients to whom they have supplied the substance or preparation within the preceding 12 months. If the chemical products you receive are for distribution, it is important that you pass on the SDS ensuring that the chemical ill continue to be used safely. If you are producing a SDS from your suppliers one it is your responsibility to ensure that the SDS is accurate.

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Are there any exemptions?
Some groups of chemicals such as medicines and cosmetics are covered by other legislation and have different rules for packaging and labelling. A SDS need not be supplied where dangerous substance or preparation offered or sold to the general public are provided with sufficient information to enable users to take the necessary measures as regards the protection of human health, safety and the environment. If you buy a dangerous chemical from a retailer for use at work, the retailer must provide a SDS if requested

What Information must be provided in the SDS?
The information to be provided in the SDS must be set out under 16 obligatory headings as laid out under Article (31) (6) and contain the information as prescribed in Annex II of the REACH Regulation. The 16 obligatory headings are given below:

1. Identification of the substance/preparation and of the company/undertaking;

2. hazards identification;

3. composition/information on ingredients;

4. first-aid measures

5. fire-fighting measures

6. accidental release measures

7. handling and storage

8. exposure controls/personal protection

9. physical and chemical properties

10. stability and reactivity

11. toxicological information

12. ecological information

13. disposal considerations

14. transport information

15. regulatory information

16. other information

Any supplier of a substance/preparation who is required under the REACH Regulation (Articles 14 or 37) to prepare a Chemical Safety Report should attach the relevant Exposure Scenarios in an annex to the SDS.

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