Keeping safety data sheets up to date presents a challenge to any manufacturer of hazardous substances. In addition to classic changes, such as adjustments to in-house formulations, there are many other causes that must be taken into consideration. Some even have far-reaching consequences, e.g. a substance that needs to be declared in Section 3, but was previously only required to be listed on a voluntary basis.
Within the context of creating and analyzing safety data sheets with GeSi³, I have come across many reasons for an update that could easily be overlooked. That is why I am providing a summary of some of the interesting ones this week.
Adaptations to technical progress
Adaptations to technical progress (ATPs) of the CLP Regulation regularly result in changes to the various areas of classification and labelling. As both the classification (Section 2.1, Section3, Sections 11 & 12) and labelling (Section 2.2) are contained in the safety data sheet, these types of changes can lead to different classifications and have an impact on what needs to be provided in the relevant sections of the safety data sheet.
Particularly worthy of note are the legal classifications, or the list of harmonised classifications in Annex VI of the CLP Regulation. This comprises classifications and labelling of particular substances that are legitimate in terms of the classification provided. Here too, the ATPs come in and change substance classifications or add new ones (deletion is a rare occurrence). If changes are made to substance classifications, this can also impact the entire mixture classification scenario.
Provision of country-based limit values
In Section 8.1, country-based limit values are provided if corresponding values are available for the ingredients in the safety data sheet. Additionally, European limit values also exist. What tends to be ignored: All ingredients with EU limit values must be identified in Section 3.
This also represents a popular starting point for SDS plausibility checks: If an ingredient and its limit values is listed in Section 8.1 and does not appear in Section 3, something is amiss. This makes for a relatively easy check.
As each member state can establish its own limit values, make amendments to them and also exclude them, the work involved in keeping all limit values up to date exponentially increases with the number of supplier countries.
REACH-related substance information
The ECHA updates the lists of substances of very high concern (SVHC – CoRAP, candidate list, list of substances subject to authorisation) several times a year. This may result in additional obligations, especially when the status of requiring authorisation is reached.
Information on dangerous goods
The various modes of transport described in Section 14 are also subject to changes at regular intervals. Formulations for certain UN numbers, their prerequisites, or even completely new hazard classes may result as a consequence of amendments. Updates to the dangerous goods law can also impact the current status of safety data sheets via Section 14.
Apart from the aforementioned amendments, there are also numerous laws at national level (Section 15), which in turn depend on the supplier countries.
Keeping safety data sheets up to date – conclusion
If you don’t want to rely on customers approaching you with information on legislative changes, you need to keep up with developments. However, keeping safety data sheets up to date is not a task you have to tackle on your own. Programs such as our SDB-Profi provide additional support by supplying you with information on updates as a consequence of legal changes. Further assistance is provided by the REACH-CLP-Biozid Helpdesk and the publications and guidelines of ECHA for any remaining questions.
Leitlinien zur Erstellung von Sicherheitsdatenblättern, Fassung 3.1 (German language version), Europäische Chemikalienagentur 2015, ISDBN 978-92-9247-514-7