Is it possible to use a European safety data sheet for the USA? After all, both jurisdictions have the same basis for SDS: GHS. Certain adaptations are nevertheless necessary. So what is different in the US-SDS? I will shed more light on this question in my next blog posts.
Where are the similarities?
Both the European and the US-SDS are based on the Globally Harmonized System (GHS). This standardizes larger parts of the content. There are similar hazard classes and categories. They are not identical, because the implementation of GHS is different for the two jurisdictions. However, there are the familiar H and P statements, signal words and pictograms in both jurisdictions. In addition, safety data sheet sections, although not identically named, are comparable thematically and in terms of sequence. This makes it easier to prepare an American safety data sheet for products where a European safety data sheet already exists.
Finding differences in the structure of the safety data sheet
The most obvious differences are in the titling of the different sections in the safety data sheets (SDS). The sections for the European safety data sheet are defined via the REACH Regulation, Annex II, Part B [1]. The MSDS consists of 16 sections, and each section also has specified subsections, such as 6.2 Environmental protection measures.
The sections and contents of the US MSDS are defined in OSHA CFR 1910.1200 App D [2]. While all sections are mandatory in the European implementation, it is possible to omit sections 12 through 15 in U.S. safety data sheets.
What happens next?
Once the American sections are established, then it’s down to the details. As mentioned earlier, there are differences in classification and labeling, for example. I will address these differences in my next blog post comparing EU and US-SDS.
Sources:
[1] Regulation (EC) Nr. 1907/2006 (REACH-VO)
[2] OSHA CFR 1910.1200 App D
